Audit-Proof Your Trade Program

Schulz Trade Law
Aug 8
4 min read

Updated: Aug 15

Cargo ship docked at a busy port with red cranes and stacked containers. Clear blue sky and calm water create a serene atmosphere. — International Trade Compliance and Customs

Audit-Proof Your Trade Program:

How Schulz Trade Law Helps You Stay Ready, Resilient, and Compliant

In international trade, regulatory audits are not a remote possibility—they are an operational certainty.

Whether initiated by U.S. Customs and Border Protection (CBP), the Bureau of Industry and Security (BIS), or the Office of Foreign Assets Control (OFAC), trade audits are increasing in frequency and scope. Enforcement agencies are scrutinizing everything from valuation and classification to licensing and supply chain transparency.

At Schulz Trade Law, we represent and advise clients facing these challenges head-on. Our goal is to ensure you don’t just react to audits—but anticipate, prepare, and respond strategically.

The New Reality of Trade Audits

In 2025, the audit landscape is evolving rapidly:

CBP is conducting more Focused Assessments, targeting valuation, tariff classification, and country-of-origin declarations.
BIS is increasing enforcement around export licensing, ECCN classification, and end-use/end-user reviews.
OFAC audits are probing compliance with sanctions regimes, especially in sensitive jurisdictions.
UFLPA enforcement is driving supply chain scrutiny around forced labor, with a presumption of noncompliance unless rebutted.

A single documentation gap, license oversight, or sourcing issue can trigger penalties, seizures, and reputational risk. And too often, companies don't realize their exposure until an agency arrives at their door.

What “Audit-Ready” Really Means Under the Law

Legal audit readiness is about proving compliance, not merely asserting good intentions.

A truly audit-ready company is able to provide:

Documented internal controls that align with regulatory expectations
Classification, valuation, and licensing determinations backed by legal rationale
Supplier and customer due diligence records
Secure and retrievable documentation (within the 5-year recordkeeping window)
Evidence of proactive risk management (training, voluntary disclosures, policy updates)

At Schulz Trade Law, we help clients build these systems and, when necessary, defend them in front of regulators.

The Cost of Being Unprepared

Non-compliance penalties can be severe—and extend far beyond monetary fines:

CBP penalties can exceed the value of the goods themselves for false statements.
BIS enforcement actions may include denial of export privileges or criminal referral.
OFAC violations can carry strict liability, even for unintentional missteps.
Detentions under UFLPA can stall shipments indefinitely, requiring supply chain transparency many companies don’t yet have.

Legal non-compliance isn’t just a paperwork problem—it’s a corporate risk.

Our Legal Approach to Building Resilient Trade Programs

We support clients through every stage of audit readiness and response:

Step 1: Legal Risk Assessment

We evaluate your program with a lawyer’s eye—identifying exposures that internal teams or outside consultants may miss.

This includes:

HTS and ECCN legal justifications
Country-of-origin support tied to preferential treatment claims
Trade agreement compliance
Licensing gaps under EAR, ITAR, and OFAC
Forced labor red flags and rebuttal documentation readiness
Recordkeeping adequacy under 19 CFR §163 and other legal standards

You receive a report of findings, with risk rankings and recommended legal remedies.

Step 2: Control Development & Documentation

We help you draft and formalize trade compliance policies that align with enforcement expectations:

Import and export compliance manuals
SOPs for documentation, screening, and license checks
Voluntary disclosure strategies for correcting past issues
Template updates for invoices, packing lists, and end-use certificates
Legal review of supplier certifications and purchase agreements

Our work product stands up to scrutiny—because we build it for that purpose.

Step 3: Training & Compliance Culture

Legal compliance only works if your team knows what’s at stake. We provide:

Live or recorded training tailored to trade, logistics, procurement, or executive teams
UFLPA rebuttal education and documentation guidance
Sanctions and restricted party list screening protocols
Training records to prove due diligence

We work with you to ensure your staff understands their legal responsibilities—and the implications of failure.

Step 4: Audit Support, Representation, and Response

When an audit notice arrives, Schulz Trade Law steps in:

We help you gather and prepare responsive documentation
Represent your interests in all written or in-person interactions with agencies
Conduct internal interviews and legal privilege reviews
Develop response narratives that mitigate exposure
If violations are found, we prepare and submit voluntary disclosures or corrective action plans

Our attorneys serve as both your legal advisors and advocates—defending your trade program from escalation or penalty.

Client Case Studies:

From Exposure to Protection

Manufacturer Facing CBP Focused Assessment

A U.S. importer was notified of a CBP Focused Assessment. Schulz Trade Law reviewed and corrected misclassified entries, updated valuation methodologies, and trained staff. The result: a clean audit outcome with no penalties—and a documented compliance program moving forward.

Exporter Under BIS Inquiry

A mid-sized exporter inadvertently shipped dual-use items without appropriate licensing. We conducted a legal ECCN review, filed a voluntary disclosure, and implemented an internal license management system. No fines were issued, and BIS closed the case without further action.

Why Clients Choose Schulz Trade Law

We are not compliance consultants. We are legal practitioners who understand the regulatory, commercial, and reputational pressures your company faces.

What sets us apart:

Depth in U.S. and global trade law, not just procedure
Experience with enforcement agencies, including CBP, BIS, and OFAC
Confidential legal privilege, allowing you to assess risk safely
Practical, executable advice, not just theoretical reviews
Defensive strategy plus program building, all in one place

Free Resource

Audit-Readiness Legal Checklist

We’ve developed a one-page, attorney-curated checklist to help assess your preparedness across CBP, BIS, and OFAC criteria.

Download the checklist here. No email required—just smart compliance hygiene.

Don’t Let an Audit Define Your Business

In the current regulatory environment, agencies are no longer asking whether your business intended to comply. They want to see that you can prove it.

If you’re facing an audit, concerned about your documentation, or want to fortify your program before enforcement arrives, Schulz Trade Law is ready to help.