Managed Recovery Program

A managed platform for complex IEEPA tariff recovery.

The IEEPA Managed Recovery Program is designed to help businesses pursue, administer, and protect tariff recoveries in an environment where the real challenge is not identifying the legal opportunity, but managing the operational burden required to turn that opportunity into money.

Filling the gap between tariff exposure and actual recovery.

Significant IEEPA refund opportunities may exist across a wide range of import transactions, but recovery is not self-executing. A potentially valuable claim does not move from theory to payment without records, timing control, customs coordination, calculation discipline, stakeholder management, and a supportable administrative process.

That is the gap the IEEPA Managed Recovery Program is built to fill.

The program provides white-glove recovery administration for Importers of Record, consignees, customs brokers, manufacturers, distributors, and other stakeholders that may be affected by challenged IEEPA tariffs. Our role is to help clients solve the practical problems that stand between tariff exposure and actual recovery.

The Operational Reality

A recovery opportunity is only as valuable as the process used to administer it.

In matters of this kind, the existence of a potential refund is only the beginning. The harder questions usually arise afterward.

These are the logistical hurdles your organization is actually paying to solve.

The IEEPA Managed Recovery Program is designed around that reality. It exists to absorb a difficult, time-sensitive, documentation-heavy problem and convert it into a structured recovery process.

Which entries qualify?
Who controls the customs record?
Were the challenged duties cleanly separated from other charges?
What do the liquidation dates show?
Who actually bore the tariff burden?
Who is entitled to payment if funds are recovered?
What happens if multiple parties assert competing rights?
What if the administrative pathway is incomplete, delayed, or disputed?
What if a matter must proceed beyond ordinary administration into protest or litigation?

Execution Methodology

What the Managed Recovery Program is

The program is a white-glove recovery-administration platform built to support the full lifecycle of IEEPA tariff recovery. It is not limited to a single filing step, a spreadsheet exercise, or a narrow document-preparation function. It is designed to support the broader chain of work that often determines whether a recovery is pursued completely, documented properly, and carried through to payment.

Depending on the matter, the engagement may include:

The objective is straightforward: to help your business pursue recovery in a way that is organized, supportable, and commercially workable.

recovery assessment and scoping;
coordination with Importers of Record, consignees, customs brokers, and other stakeholders;
collection and normalization of customs and commercial records;
entry identification and tariff reconstruction;
liquidation and timing review;
support for customs-administered refund pathways, including ACE-related workflows;
principal and interest analysis;
downstream allocation and claimant coordination where required;
release and payment-administration support;
maintenance of an audit-ready recovery file; and coordination with qualified legal counsel where protests or CIT proceedings become necessary.

Target Demographics

The problems the program is designed to solve

The program is built for stakeholders facing recurring recovery problems that are substantial in practice, even where the legal theory may be favorable. These are not abstract legal concerns. They are the administrative burdens that determine whether money is actually recovered.

Importers of Record

Sophisticated Importers refuse to receive and distribute funds without a defensible framework. They must identify all qualifying entries, gather historical data, determine burden, and administer a recovery stream that benefits downstream parties.

Consignees & Downstream

Smart consignees refuse to remain dependent on upstream parties. They absorbed the tariff burden economically, but do not control the customs entry. Their challenge is to assemble the record and trace the duties.

Customs Brokers

Our broker partners rely on us to contain professional exposure. Brokers sit closest to the record but do not want to internalize the operational risk of running a full claims-administration program.

Manufacturers & Distributors

They may have passed through tariff cost across large volumes of transactions. Their problem is one of value realization: translating economic burden into a documented recovery position tied to identifiable entries.

Small & Mid-Sized Businesses

Your business should not be forced to build a temporary internal recovery department. Smaller enterprises lack the personnel needed to coordinate brokers, records, submissions, and payment administration.

Core Disciplines

A comprehensive approach to recovery administration

White-glove administration from record assembly through payment

The program is intentionally high-touch. IEEPA recovery matters frequently require coordination across multiple internal and external participants, including finance teams, customs brokers, Importers of Record, downstream claimants, advisors, and legal counsel. A fragmented process can create confusion, missed opportunities, and later disputes.

Our approach reduces that friction. We manage intake, organize data collection, structure workflows, track administrative posture, and maintain visibility into payment and downstream administration.

The value is that the work is done within a more disciplined structure—one that supports speed, clarity, repeatability, and defensibility.

Forensic recovery support and customs-administration discipline

The value of a recovery opportunity can be materially reduced if the supporting analysis is incomplete. Recoverable amounts are often understated because entries were not fully captured or challenged duties were not accurately isolated.

We address that risk through forensic recovery support. We collect and normalize historical records, identify entries potentially affected by challenged IEEPA duties, analyze amounts, and build a complete recovery record.

Recovery requires more than a view about entitlement. It requires disciplined administration.

Allocation, distribution, and stakeholder coordination

For many matters, the most sensitive work begins after a recovery has been identified. A refund may implicate multiple parties across the supply chain. Consignees, customers, or distributors may each assert some form of entitlement.

Absent a structured process, that can lead to confusion, avoidable disputes, and disbursements made without adequate protection. We administer those issues in an organized way, including claimant coordination, allocation analysis, and release workflows designed to preserve commercial order.

For many clients, this is not a side issue. It is the core problem they are trying to solve.

Audit-ready administration and supportable records

Recovery should not end with a payment and no clear explanation of how the result was reached. Particularly where significant dollars are involved, clients need a record that can support later scrutiny from auditors, lenders, counterparties, or governmental authorities.

The program emphasizes supportable administration. We preserve the data, methodology, date tracking, supporting documentation, and administrative history so that the matter can be explained later if necessary.

In complex recoveries, value is not created by payment alone. It is created by payment that can withstand review.

Coordination with qualified legal counsel where needed

Although many recovery issues are fundamentally administrative, not every matter will end there. Certain matters may require formal protests, litigation strategy, or proceedings before the Court of International Trade in order to secure or protect recovery.

The Managed Recovery Program is designed with that possibility in mind. We build the administrative and evidentiary record so that, where escalation becomes necessary, qualified legal counsel is working from an organized and supportable file rather than fragmented customs reports.

This allows administration and legal strategy to function as part of a coordinated whole.

Risk Profiles

Why clients use a managed recovery platform

Our clients do not engage this platform because they desire more process. They engage us because unmanaged recovery creates unacceptable commercial risk.

The Managed Recovery Program allows your organization to trade a difficult recovery problem for a structured service designed to mitigate these precise exposures:

A failure to manage these issues internally guarantees value is left on the table.

A claim may be underinclusive because qualifying entries were never fully identified.
A recovery may be delayed because records were fragmented across brokers and systems.
A claimant may fail because the economic burden was never properly tied to the customs record.
An Importer of Record may receive funds without a defensible framework for downstream allocation.
A consignee may be left dependent on upstream parties without visibility into the path to payment.
A broker may be drawn into a dispute-management role its service model was not built to carry.
A business may miss important statutory timing issues while trying to organize the file.
A later audit or government inquiry may expose that the recovery was never documented properly.

Take Action

A platform engineered to carry the burden your business should not have to bear.

The money matters, but the work required to recover it is substantial.

Whether you are an Importer of Record, consignee, customs broker, or manufacturer affected by challenged IEEPA tariffs, the Managed Recovery Program is designed to execute the burden: from record assembly and customs coordination through payment, allocation, audit protection, and legal escalation.

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