Recovery Execution

Forensic Recovery Analysis

Identifying the existence of IEEPA tariffs is only the beginning. Recovery often turns on a more difficult exercise: reconstructing the entry record, determining who bore the economic burden, quantifying recoverable amounts, and building a supportable file.

In many IEEPA matters, the principal challenge is not recognizing that a potential refund opportunity may exist. It is determining, with precision, what the recoverable claim actually is.

That work is rarely mechanical. It requires reviewing large populations of entries across multiple periods, reconciling ACE data against broker reports, identifying where challenged duties were embedded, analyzing liquidation posture, and evaluating whether the party controlling the entry actually absorbed the tariff burden.

The Forensic Recovery Analysis function helps clients move from a generalized sense of exposure to a documented, supportable, and administrable recovery position.

The Analytical Bridge

More than tariff identification

Tariff identification asks what was paid. Forensic analysis goes materially further, acting as the bridge between tariff recognition and actual recovery.

Quantification

Determining exactly what amounts are potentially recoverable across the entire dataset.

Completeness

Validating whether all qualifying entries have been accurately captured and isolated.

Administrative Posture

Reviewing what the liquidation and reliquidation history shows for the affected entries.

Interest Analysis

Evaluating whether statutory interest should be included in the total recovery model.

Economic Burden

Tracing who actually bore the economic burden of the tariffs through the supply chain.

Defensibility

Structuring how the resulting recovery position should be documented, administered, and defended.

Execution Methodology

Translating data into supportable claims

Entry-level reconstruction and validation

The customs record must be reconstructed before the recovery opportunity can be understood accurately.

Historical entries may be spread across multiple customs brokers, importer numbers, operating entities, and internal record systems. Entry Summary data may not be uniform across periods. Additional duties may not have been broken out in a way that makes the IEEPA component immediately clear.

We address that complexity through disciplined entry-level review. We analyze the available record, reconcile inconsistent datasets, identify potentially affected entries, and test whether the duty picture reflected in one source aligns with others.

That work is often where the recovery opportunity becomes more complete—or where weaknesses in the record are identified early enough to be addressed.

Economic-burden tracing and claimant analysis

In many matters, the party that made the customs entry is not the only party with an economic stake in the recovery.

An Importer of Record may have passed the tariff burden downstream through pricing or reimbursements. A consignee may have absorbed the cost without controlling the customs entry. A manufacturer or distributor may have funded the burden through a broader commercial structure.

We help connect the customs-facing data to the commercial record. That may include tracing the burden of payment across invoices, landed cost, internal transfers, or customer arrangements.

That work is central to determining not only how much may be recoverable, but who is entitled to recover it.

Economic-Burden Tracing and Claimant Analysis

Capturing the full recovery opportunity

A client may have a strong entitlement position in principle, yet leave material value unrecovered because qualifying entries were never fully identified or historical data was accepted at face value without validation. We review whether:

all relevant entry periods have been captured;
all affected countries and tariff actions have been included;
all relevant brokers and data sources have been consulted;
product-specific modifications or exclusions affect the calculation;
supplemental deposits or timing issues alter the recoverable amount; and
the working recovery model reflects the full scope of what may be claimed.

In many matters, this is where value is created.

Principal and interest analysis

In a significant recovery matter, the principal tariff amount is only part of the analysis.

The timing of deposits, liquidation events, and refund processing can affect whether interest should be tracked as part of the broader recovery position. Where applicable, that requires a disciplined view of the entry history, not simply a rough estimate.

Our forensic work quantifies the core recovery amount and evaluates the interest component in a way that aligns with the underlying record.

Allocation support and downstream administration

Where multiple stakeholders assert a right to recovery, the forensic work becomes an allocation exercise. The question becomes:

who paid it in economic substance;
what portion of the recovery may relate to each stakeholder;
what support exists for that allocation; and
how the distribution process should be administered without conflict.

Our analysis supports that downstream work by creating a reliable foundation for allocation, claimant coordination, release workflows, and disbursement.

Detecting anomalies, inconsistencies, and hidden risk

A meaningful forensic review should do more than confirm expected amounts. It should surface what may be wrong with the file. That may include:

duties that appear inconsistent across brokers or periods;
product classifications that may affect tariff treatment;
country-of-origin issues that affect the applicable rate;
unexpected differences between ACE data and internal reporting; or
incomplete commercial support for burden tracing.

Identifying those issues early is not simply good housekeeping. It is a form of risk management.

Risk Management

The problems this work is built to solve

Clients typically engage forensic recovery analysis because they know IEEPA tariffs were paid, but do not know:

whether all qualifying entries have been identified;
whether the reported amounts accurately isolate the challenged duties;
whether multiple brokers created inconsistencies in the record;
whether the customs-facing party is the party that bore the tariff burden;
whether liquidation timing affects the administrative pathway;
whether downstream claimants may assert competing rights to funds; or
whether the matter could withstand later scrutiny by auditors or counsel.

These are precisely the kinds of burdens that a managed forensic process is designed to absorb.

Audit-ready and litigation-supportable records

Forensic analysis should culminate in more than a calculation. It should result in a file that can withstand scrutiny from auditors, lenders, counterparties, or governmental authorities.

We help preserve the underlying data, the methodology used to analyze it, the assumptions applied, and the reasoning supporting the resulting recovery position.

A recovery opportunity has greater value when the analysis behind it can be definitively defended.

Why clients use a managed forensic process

Clients do not engage forensic analysis because they want more complexity. They engage it because unmanaged complexity creates risk. A recovery may be understated if entries are missed. A claimant position may weaken if economic burden is not traced properly. A distribution may become disputed if the allocation logic is not documented.

Forensic Recovery Analysis exists to reduce those risks by replacing assumption with validation and fragmentation with structure.

It allows clients to trade a difficult analytical problem for a managed process designed to solve it.

Take Action

A recovery opportunity is only as strong as the analysis behind it.

The Forensic Recovery Analysis function is designed to help clients identify the full recovery opportunity, quantify it with precision, evaluate who is entitled to it, and support the matter through refund administration, allocation, and dispute.

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