The Commerce Control List in all its glory. The Commerce Control List (CCL) is a critical part of export controls under the U.S. Export Administration Regulations (EAR). This webinar offers a comprehensive overview of the CCL, breaking down its structure, categories, and the nuances of classification. We’ll guide you through the essential steps to correctly determine the classification of items and provide tips on how to stay compliant with export regulations.
Year-End Trade Compliance Checklist: Prepare for a Successful 2025
Year-End Trade Compliance Checklist: Prepare for a Successful 2025
Nic Arters
Director, Star USA
As our Star USA team ramps up to next year, I can’t help but reflect on the trade compliance landscape of 2024. The global trade landscape shifted with new regulations, evolving sanctions, and technological advancements, making trade compliance a moving target. Next year looks like it will be similar.
To smooth over potential issues before they happen, I’ve created a useful checklist to help compliance professionals prepare for a successful 2025. Now is the perfect time to help ensure your trade compliance programs are ready for the challenges and opportunities of the year ahead.
Read on for the top seven steps to confidently close the year and set your business up for global success!
Why is This Important Now?
Before we jump into our checklist, let’s level set. Here’s why a buttoned-up trade compliance checklist is crucial for 2025:
- Regulatory shifts: A new administration often brings changes in trade policies and regulations. Staying informed helps businesses adapt quickly to new requirements.
- Geopolitical risks: Ongoing global tensions can lead to new trade sanctions and export controls. Being prepared helps mitigate potential disruptions to international operations.
- Technological advancements: The trade compliance landscape is evolving with new technologies like AI and blockchain. Adapting to these changes can improve efficiency and reduce risks.
- Supply chain scrutiny: There's an increasing focus on supply chain transparency and ethical sourcing. Preparing for stricter regulations like the Uyghur Forced Labor Prevention Act is crucial.
- Competitive advantage: Companies that proactively address compliance issues are better positioned to navigate the complex global trade environment.
- Potential tariff changes: A new administration may implement significant changes to tariff structures, which could impact import/export costs and supply chain strategies.
Now, we can review the important items to have on your to-do list in the coming weeks!
1. Conduct a Comprehensive Internal Compliance Audit
- Action: Perform a thorough review of all compliance processes and documentation.
- Rationale: Identify and address potential compliance gaps.
Your first step is to evaluate the health of your compliance program by conducting a full internal audit. This includes reviewing processes, records, and communication channels to comply with relevant import and export regulations.
This exercise isn’t about pointing fingers—it’s about identifying areas for improvement. Proactively addressing gaps can reduce risks and establish a strong foundation to tackle challenges ahead.
2. Update Restricted Party Screening Procedures
- Action: Review and update screening lists and processes.
- Rationale: Help ensure compliance with the latest sanctions and export controls.
With sanctions and trade restrictions frequently changing, outdated screening processes can lead to costly mistakes. Take the time to verify your restricted party screening procedures are up to date.
Cross-reference your lists with the latest updates from government agencies such as the Departments of Commerce, State, and Treasury. I like to direct clients to this Department of Commerce consolidated export screening list. It’s also helpful to review Don’t Let This Happen to You from the Bureau of Industry and Security for real consequences of violating U.S export control law.
If you haven’t already, you may also want to implement automation tools to make your screening efforts more efficient. Staying current protects your business from unintentional violations and reinforces your reputation as a reliable trade partner.
And Importers, please don't overlook the UFLPA Entity List! It receives continuous updates and this list is not part of the consolidated export screening lists.
3. Review and Update Compliance Training Programs
- Action: Assess current training materials and schedule updates for 2025.
- Rationale: Keep staff informed on the latest regulations and best practices.
Trade compliance isn’t a one-person job: it’s a team effort. Ensuring your staff understands their role in maintaining compliance is critical. I recommend that you review your training materials to make sure they reflect the most current regulations and industry standards.
The U.S. Department of Justice recently updated their guidance for evaluating internal compliance programs; senior leadership teams need to actively prioritize these fundamental elements for a chance at successfully navigating enforcement actions.
Supplement Your Internal Training
Star USA experts offer live export compliance
training sessions.
For 2025, consider incorporating training on emerging topics like supply chain transparency and ethical sourcing regulations, including the Uyghur Forced Labor Prevention Act. A well-informed team can prevent costly errors and strengthen your overall compliance efforts.
4. Assess the Impact of New Trade Agreements and Regulations
- Action: Review new agreements and regulations, updating internal policies as needed.
- Rationale: Adapt compliance programs to the changing trade landscape.
Trade agreements and regulations are in constant flux. Whether it’s updates to the United States-Mexico-Canada Agreement (USMCA), new export controls, or shifts in tariff structures, staying ahead of these changes is crucial. Because the 2026 USMCA joint review requires preparations in 2025, I believe compliance professionals should have it on their radars starting now.
Identify the regulations most relevant to your business and analyze their potential impact. Then, update your internal policies and procedures accordingly to stay compliant and avoid disruptions. This can be a daunting task to complete alone. If you need support, our team can help you make informed import-export compliance decisions.
5. Update Export Control Classification Procedures
- Action: Review and update product classifications under EAR and ITAR.
- Rationale: Facilitate accurate classification under EAR and ITAR.
Proper classification is the cornerstone of compliance. A misclassification could lead to shipment delays, penalties, or worse. Review your product classifications so they align with the latest EAR and ITAR guidelines.
If you’ve introduced new products or modified existing ones, prioritize those updates. Taking these steps now helps you avoid surprises down the road and keeps your exports moving smoothly.
6. Review and Update Customs Valuation Methodologies
- Action: Assess current valuation practices and implement any necessary changes.
- Rationale: Create accurate and compliant customs declarations.
Customs valuation is often overlooked until issues arise. Take time to review your valuation methodologies to help ensure they align with international standards and regulations. Accurate valuation minimizes the risk of fines, delays, and audits. It also demonstrates your commitment to fair trade practices, enhancing your reputation with customs authorities and partners.
7. Update Harmonized Tariff Schedule (HTS) classifications
- Action: Review and update product classifications based on the latest HTS.
- Rationale: Ensure accurate duty calculations and compliance.
Keeping your HTS classifications current can help avoid disruptions in your supply chain and create smooth cross-border transactions. Changes to the HTS can impact duty rates, eligibility for trade agreements, or import/export compliance requirements.
I recommend conducting a year-end review of classifications helps prevent errors that could lead to audits or fines while optimizing costs for your clients. Proactive measure can also help you demonstrate your commitment to precision and regulatory excellence!
Position Yourself for 2025 Success
A solid trade compliance program is more than a regulatory requirement—it’s a competitive advantage. By following this checklist, you can help ensure compliance and position your business to thrive in our rapidly changing global trade environment.
At Star USA, our clients gain access to a team of seasoned experts with a proactive, comprehensive, and proven approach to trade compliance. Our global experience, including participation in Customs events across multiple continents and deep relationships with various government entities, helps clients prepare for 2025's challenges and opportunities.
We've helped companies avoid millions in potential penalties, streamline cross-border operations, and turn regulatory challenges into strategic advantages. Our team stays current with regulations, providing efficient, effective solutions that minimize disruption to core business operations.
Let’s start 2025 confidently, ready to navigate the complexities of global trade and unlock new avenues for growth. Contact my team for support at any point along the way.
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