Who We Serve

Built for the stakeholders who bear the burden of recovery

The IEEPA Managed Recovery Program is designed for the businesses and professional stakeholders that must do more than recognize a potential refund opportunity. They must identify affected entries, assemble fragmented records, quantify tariff exposure, address competing economic claims, and administer recovery in a way that is commercially workable and supportable.

In complex tariff matters, money does not move without friction. The party that made entry may not be the party that bore the economic cost. The party that absorbed the cost may not control the customs records. The party best positioned to identify the claim may not be staffed to administer the recovery. And once funds are recovered, the hardest questions often begin: who is entitled to what, based on which records, under what methodology, and with what protection against later dispute.

The IEEPA Managed Recovery Program is built for that environment. We serve the stakeholders who face the operational, evidentiary, and commercial burdens that stand between a theoretical refund opportunity and an orderly, supportable recovery.

A platform designed for stakeholders with real exposure

Recovery opportunities of this kind are rarely self-executing. They create work. They create timing pressure. They create documentation demands. They create allocation questions. They create the risk that one party will receive funds that another party believes it funded, absorbed, or is entitled to share. They create the risk that organizations will be forced to reconstruct years of customs and commercial history under significant time constraints and with incomplete records.

That is the environment in which we operate.

The program is designed for stakeholders whose problems are not abstract. Their problems are practical: identifying affected entries, gathering data across brokers and systems, isolating challenged duties from other charges, tracing economic burden across a transaction chain, structuring supportable demands, coordinating stakeholder communications, and administering distributions without creating avoidable downstream conflict.

Where those burdens exist, managed recovery becomes valuable because it converts a diffuse administrative problem into a disciplined recovery process.

Who the program is designed to support

Importers of Record

Importers of Record often face the most immediate administrative burden. They may control the customs entry, but not the full commercial story behind the tariff burden. They may be the first recipient of a refund, yet not the only party with a plausible claim to recovered funds. They may need to identify affected entries across years, brokers, entities, and product lines while also determining whether customers, consignees, affiliates, or other downstream parties funded or absorbed some portion of the duties.

For these clients, the problem is not merely whether recovery may be available. The problem is how to pursue that recovery without missing timing issues, relying on incomplete data, misallocating funds, or inviting post-recovery disputes. The Managed Recovery Program is designed to help Importers of Record bring structure, methodology, and defensible administration to that process.

Consignees and downstream parties

Consignees and other downstream stakeholders often face a different but equally difficult problem: they may have borne the economic cost of the tariffs without controlling the customs entry itself. In practical terms, that means they may believe they paid the burden through landed cost, reimbursements, chargebacks, transfer pricing, or commercial arrangements, but lack direct possession of the customs record needed to prove it.

For these stakeholders, recovery depends on building a supportable claim from incomplete visibility. That may require tracing tariff cost through invoices, payment records, broker data, pricing history, and commercial documentation, and then translating that record into a structured demand or allocation position that can be presented to an Importer of Record, broker, or other decision-maker. The Managed Recovery Program is built to help solve that problem.

Customs brokers

Customs brokers occupy a critical position in many recovery matters because they often hold, control, or help interpret the records necessary to reconstruct the entry history. At the same time, brokers are not always engaged to run a multi-party recovery administration project, quantify downstream economic burden, coordinate allocation disputes, or maintain the type of comprehensive recovery file that clients and their advisors may later require.

For brokers, the problem is often one of client need exceeding ordinary engagement scope. Clients need data extraction, historical reconstruction, timing support, and administrative coordination, but the recovery effort may require a broader managed process than a broker is staffed to provide internally. The Managed Recovery Program is designed to work alongside brokers in that setting, helping convert customs data into a structured recovery workflow.

Small and midsize businesses

Many small and midsize businesses may have meaningful tariff exposure but lack a dedicated customs team, internal recovery personnel, or the administrative depth required to coordinate a large-scale recovery effort. Their problem is not the absence of a claim. It is the absence of internal infrastructure.

For those businesses, the recovery process can become overwhelming quickly: records are dispersed, brokers may have changed over time, internal personnel may not know where historical support lives, and the financial stakes may be large enough that mistakes in calculation, allocation, or documentation carry real consequences. The Managed Recovery Program is designed to provide the operating capacity those organizations do not maintain in-house.

Corporate groups and multi-entity organizations

For corporate groups, the problem is often scale combined with fragmentation. Entries may sit across multiple legal entities. Brokers may vary by business line, geography, or time period. Tariff burden may have been funded, transferred, or absorbed across affiliates. Internal data may live in disconnected finance, procurement, customs, and supply-chain systems. And once recovery begins, the organization may need a unified method for evaluating entitlement, coordinating claims, and documenting decisions across the enterprise.

The Managed Recovery Program is built for that level of complexity. We help create centralized structure where the underlying facts, records, and stakeholders are dispersed.

Manufacturers, distributors, and supply-chain participants

Not every affected stakeholder made entry. In many commercial arrangements, manufacturers, distributors, procurement entities, and other supply-chain participants may have borne part of the economic burden through price concessions, reimbursement obligations, pass-through arrangements, or downstream commercial adjustments.

For these stakeholders, the problem is often proving economic impact in a way that can be connected back to identifiable entries and documented in a form that supports recovery, allocation, or demand. The Managed Recovery Program helps bridge the gap between commercial burden and supportable recovery analysis.

Manufacturers, distributors, and supply-chain participants

Importers of Record engage the program because they do not want to receive funds without a supportable framework for evaluating downstream claims, allocating recoveries, and documenting why distributions were made the way they were.

Consignees and downstream parties engage the program because they do not want a valid economic claim to fail merely because they do not control the customs entry or the broker file.

Customs brokers engage the program because their clients’ recovery issues often require more than record access—they require coordinated administration, repeatable methodology, and structured stakeholder handling.

Businesses and advisors engage the program because this work is time-consuming, documentation-intensive, commercially sensitive, and highly vulnerable to error when handled informally.

In that sense, the program exists to solve a recurring commercial reality: parties trade money problems for service providers that can absorb the burden, reduce the error risk, and move the matter toward a cleaner outcome. That is the role we are built to play.

The problems we are built to solve

Across stakeholder categories, the problems tend to recur in recognizable forms:

the records are fragmented across brokers, systems, entities, and time periods;
the challenged tariffs are not cleanly separated from other duties or charges;
the organization lacks a reliable way to identify which entries are affected;
the party with the claim does not control the underlying customs record;
the party receiving funds may face competing downstream demands;
allocation decisions must be made in a commercially defensible manner;
communications among stakeholders must be organized before positions harden; and
the entire process must be documented in a way that can withstand later review.

Those are managed recovery problems. They are precisely the problems the program is intended to address.

Methodology

Not merely claim support—recovery administration

The program is not limited to identifying whether a theoretical refund may exist. It is designed to help administer the broader recovery chain, which may include data intake, record collection, entry identification, tariff reconstruction, timing review, economic-burden analysis, stakeholder claim support, allocation methodology, release coordination, payment administration, and maintenance of an audit-ready file.

That distinction matters. In complex recovery environments, value is often created not by recognizing that money may be available, but by solving the administrative problems that prevent that money from being recovered and distributed in a controlled way.

Ecosystem

A collaborative model across the recovery chain

The stakeholders we serve are often already working with customs brokers, accountants, consultants, in-house personnel, and legal counsel. Our role is designed to be complementary. We do not assume that recovery should be handled in isolation from the broader advisor ecosystem. We assume the opposite: that effective recovery in complex matters usually requires a coordinated structure in which different participants handle different forms of risk and workload.

Our role within that structure is to provide recovery-administration infrastructure, documentation discipline, workflow management, and operational support so that the matter does not depend on improvised spreadsheets, incomplete records, or ad hoc stakeholder handling.

Find the path that fits your role

Whether you are the Importer of Record, a consignee seeking to quantify tariff burden, a customs broker supporting affected clients, or a professional advisor confronting a recovery opportunity that requires more infrastructure than advice alone, the IEEPA Managed Recovery Program is designed to help absorb the burden and bring the matter under disciplined administrative control.

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