Client Profile

Small and mid-sized businesses often have a real recovery opportunity, but not the internal infrastructure to pursue it efficiently.

We help solve the practical problems that usually prevent recovery from being handled cleanly: broker coordination, data gathering, submission support, payment tracking, deadline management, current CBP guidance, and audit-ready recordkeeping.

Small and Mid-Sized Business Administration
The Operational Reality

A recovery opportunity can quickly become an administrative burden.

Small and mid-sized businesses often do not maintain a dedicated customs team, in-house recovery personnel, or the administrative infrastructure required to manage a complex tariff refund process from start to finish. Records may be dispersed. Broker relationships may have changed over time. Internal support may sit across finance personnel, operations teams, outside brokers, and archived files.

The result is familiar: the business may have money at stake, but recovering it requires more work, organization, and procedural discipline than the business is built to carry on its own.

“The problem is not only identifying the refund. It is managing the process required to get paid.”

Whether or not you are the Importer of Record


Direct Customs Filing
Scenario A

Direct Importer of Record

Some small and mid-sized businesses are themselves the Importer of Record and need support identifying qualifying entries, gathering customs data, and pursuing refunds directly through the applicable customs-administration pathway.

Scenario B

Downstream Economic Burden

Others are not the Importer of Record. The business may have borne the economic burden of the tariff while the customs entry was made by an upstream importer or intermediary. We help document your position, coordinate with the Importer of Record, and monitor whether funds ultimately flow through the proper channel.

Supply Chain Administration
Platform Capabilities

How the program supports small and mid-sized businesses

Depending on the matter, our platform provides the operational capacity these organizations do not maintain in-house.

Broker Coordination & Data Gathering

Customs data may sit with current or former brokers, or require reconciliation across multiple sources. We work with businesses and their brokers to gather relevant records and ensure the recovery process begins with a usable data set.

Tracking Refunds & Payment Flow

Whether funds are expected directly from CBP or through an upstream Importer of Record, we help businesses monitor the status of recovery and payment flow so they are not left uncertain about where the matter stands.

Deadlines & Procedural Discipline

We help clients maintain procedural discipline by tracking important timing considerations, staying current on relevant CBP developments, and ensuring the recovery effort remains aligned with administrative demands.

Audit Protection & Administration

Recovery should not end with the receipt of funds. We help maintain a supportable, audit-ready recovery file so the business is not left trying to reconstruct the basis for recovery after the fact.

The problems small and mid-sized businesses are usually trying to solve


Businesses in this category typically come to the program because they are facing one or more of the following problems:

“A supportable recovery requires more than a claim. It requires records, timing control, payment visibility, and disciplined administration.”

  • they do not know which entries may qualify for refund;
  • they do not have a complete set of historical customs records;
  • the necessary data is held by one or more customs brokers;
  • they are not sure whether recovery should be pursued directly or through an Importer of Record;
  • they need help submitting or supporting refund requests through the applicable process;
  • they want to track whether payment is expected from CBP directly or through an upstream party;
  • they need a structured process for monitoring deadlines and procedural developments;
  • they want a supportable administrative record in case the recovery is questioned later.
Take Action

A meaningful recovery should not require you to build a customs-administration department overnight.

If your business may have paid or absorbed IEEPA tariffs, the Managed Recovery Program is designed to help you solve the practical problems that stand between you and recovery.