Renee Chiuchiarelli & Julie Parks

March 25, 2026

~10 minutes

Global Training Center

In this final episode of the Org Structures series, Renee and Julie bring everything together with real-world “what would you do?” scenarios that highlight how trade compliance structures actually perform under pressure.

From centralized bottlenecks to decentralized chaos, they walk through common organizational models and—more importantly—how to fix the gaps using practical tools like RASCI frameworks, operational controls, and accountability mapping.

The key message?

Trade compliance structure directly impacts:

Clearance speed

Audit exposure

Broker performance

Internal escalation

If roles aren’t clearly defined, risk increases. If they are, compliance becomes operational and defensible.

A RASCI model helps define:

R (Responsible): Executes the task

A (Accountable): Owns the outcome

S (Support): Assists execution

C (Consulted): Provides input

I (Informed): Kept in the loop

Without this clarity, work gets duplicated—or worse, dropped entirely.

Every model has strengths and gaps:

Centralized: Strong control, slow execution

Decentralized: Fast locally, inconsistent globally

Matrix: Flexible, but can create decision confusion

👉 The solution isn’t choosing the “right” model—

Policies alone don’t work.

You need operational controls, such as:

Required data fields in systems

Dual classification reviews

Approval workflows for high-risk shipments

Embedded export screening checkpoints

Standardized broker instructions

These turn compliance from theory into execution.

When compliance is spread across teams with no clear owner:

Tasks fall through the cracks

Accountability disappears

Risk increases

The fix:

In complex orgs, success comes from:

Cross-functional collaboration

Clear escalation frameworks

Defined decision boundaries

As Renee and Julie highlight:

If you’re working in a matrix or hybrid structure:

👉 Stop trying to own everything.

Instead:

Map a simple RASCI for one process (start small)

Example: classification reviews or CF-28 responses

Define:

Who executes

Who owns the outcome

Who must be consulted

Identify gaps in accountability

🎯 The goal:

How is your trade compliance function structured today?

Centralized?

Decentralized?

Matrix?

Something in between?

👉 Head over to the Trade Geeks community and share:

Your structure

Your biggest challenge

How you’re applying this week’s FIO

Hosts:

Producer:

New TIPS episodes every Tuesday.

Presented by:

Simply Trade Podcast on LinkedIn

Global Training Center on LinkedIn

YouTube

Spotify

Apple Podcasts

Trade Geeks Community

💬 Don’t forget to rate, review & share with your fellow trade geeks!

📧 [email protected]

Cindy Allen – CEO, TradeForce Multiplier

Pete Mento – Director, Global Trade Advisory, Baker Tilly

March 24, 2026

~42 minutes

Welcome to a special edition of Simply Trade—The Pete & Cindy Show.

In this episode, industry veterans Cindy Allen and Pete Mento take the mic for a candid, unscripted conversation on the current state of global trade. With no guests and no filters, the two dive into real-world challenges, industry trends, and the evolving role of trade professionals.

Blending humor, sharp insight, and deep experience, Cindy and Pete break down complex trade topics in a way that’s both practical and engaging. From tariff pressures to business strategy, this episode feels less like an interview—and more like sitting in on a conversation between two of the industry’s most respected voices.

Why today’s trade environment demands both technical expertise and business awareness

How leaders in trade are adapting to constant regulatory and economic shifts

The importance of communication and storytelling in trade compliance

How humor and personality can play a role in making complex topics accessible

Why experienced professionals are rethinking how they engage with the next generation of trade talent

Trade is no longer just operational—it’s strategic and highly visible

The best insights often come from open, unstructured conversations

Industry leaders must balance compliance, economics, and business realities

Authenticity and personality matter more than ever in education and content

Sometimes, the most valuable discussions happen when you drop the formal format

TradeForce Multiplier

Baker Tilly Global Trade Advisory

Simply Trade Podcast

Host: Cindy Allen

Host: Pete Mento

Produced by Lalo Solorzano

🎧 Spotify: https://open.spotify.com/show/09m199JO6fuNumbcrHTkGq?utm_source=SimplyTradePodcast

🍎 Apple Podcasts: https://podcasts.apple.com/us/podcast/simply-trade/id1640329690?utm_source=SimplyTradePodcast

📺 YouTube: https://www.youtube.com/@simplytradepod?utm_source=SimplyTradePodcast

Global Training Center: https://www.linkedin.com/company/global-training-center?utm_source=SimplyTradePodcast

Trade Geeks Community: https://globaltrainingcenter.com/portal/?utm_source=SimplyTradePodcast

Have insights on trade, customs, or global logistics?

Host: Annik Sobing

Lessons from Applied Materials: Export Controls, Entity List Risks, and Semiconductor Enforcement

Annik Sobing welcomes Valentin Povarchuk, trade compliance expert with 20+ years across big law, in-house, and boutique firms, for a deep dive into export controls and sanctions—his thought leadership sweet spot. They unpack the Applied Materials $252M settlement for ion implanter sales to SMIC (despite BIS warnings and Entity List designation), Pterodyne Flare’s $1M mitigated penalty (via voluntary disclosure), and how companies navigate entity list risks in semiconductors amid U.S.–China tensions. Valentin teases an April 7 free GTC webinar on due diligence.

Valentin’s background

20+ years advising on customs, AD/CVD, export controls, sanctions; now at Acrevis Law Group helping companies (esp. tech/startups) build compliance programs.

Expert in entity list/entity alerts, corporate risk management—not just tariffs/customs.

Semiconductor export controls 101

Focus on equipment/software for advanced chips (AI training), not just chips themselves; bipartisan consensus on China as tech adversary (Russia/Belarus secondary).

Biden’s AI Diffusion Rule (global licensing limits) revoked by Trump; new approach more “transactional” (trade for access). Uncertainty reigns—no clear replacement yet.

Applied Materials case breakdown ($252M penalty)

BIS sent is-informed letter warning off SMIC; later Entity List addition. Applied continued via South Korean plant (substantial transformation: assembly/testing to claim “Korean origin” <25% U.S. content).

BIS rejected: Substantial transformation irrelevant for Entity List sales (no clear reg definition of “foreign-made” under EAR); “spirit of restrictions” trumps letter. Intentional strategy, not mistake—revenue pressure (competitors ready).

Risk management realities

Is-informed letters = stop sign for regulators (not yellow light); license applications possible but slow/uncertain amid brain drain at BIS.

Balance: Compliance vs. business survival (e.g., 25% revenue at risk); competitors lurk. Bigger firms targeted harder.

Practical advice for companies

Screen addresses + entities; diligence/parties/end-users critical.

Smaller tech/startups: Contract language, certifications, compliance programs mitigate risks without killing deals.

Export controls > tariffs now; semicon/tech under microscope—review Entity List diligence today.

Is-informed = hard stop; don’t “get creative” without weighing enforcement (spirit > letter).

Voluntary disclosure works—self-report transparently for leniency.

Join Valentin’s free April 7 GTC webinar on due diligence.

Credits

• YouTube

Join the conversation with fellow trade professionals in the Trade Geeks Community:

Host: Cindy Allen

Wishlist: Importers Just Want IEEPA Refunds + CBP’s New “Customs Business” Bombshell

Cindy Allen delivers her signature Taylor Swift–inspired trade update (“Wishlist” from the latest album), channeling importers’ singular desire: “I just want you, Mr. Refund.” She covers DHS budget chaos, petrodollar threats from the Strait of Hormuz closure, Jones Act waiver talks, and a seismic CBP ruling that redefines classification, OCR, and CF-5106 work as customs business.

DHS funding crisis

No Congressional budget agreement—TSA, FEMA, non-LEO CBP staff (Office of Trade, admins) not getting paid; TSA lines lengthening as agents take second jobs.

CBP officers funded via prior “big beautiful bill,” but broader agency operations strained. No impact yet from Kristi Noem’s DHS exit.

Strait of Hormuz & petrodollar shift

20–40% of world oil flow halted; India secured safe passage deal, China negotiating oil payments in yuan—challenging petrodollar system (U.S. dollar as reserve currency since 1970s OPEC deal).

Could erode USD value, force global banks to rethink reserves, impact U.S. debt/economy beyond just gas prices (countries releasing strategic reserves for short-term relief).

Jones Act & USMCA updates

Administration eyeing Jones Act waivers for chemicals, energy, fertilizers to ease oil crisis transport limits.

U.S.–Mexico technical teams meeting regularly on USMCA progress (extension preferred over renegotiation); Canada tensions delay trilateral talks. Trump postpones China trade trip.

CBP bombshell: HQ 350722 ruling

Internal advice ruling deems OCR conversion of shipping data, classification for importers, and CF-5106 filings (importer/ultimate consignee setup) as “customs business” requiring licensed customs brokers.

Overturns prior practice where importers could use non-broker consultants for these (often to check broker work or build databases). Likely legal challenges ahead; chills AI/OCR tools offered directly to importers.

Importers want simple answers on CBP’s CAPE refund process (Excel declarations via ACE)—but open questions persist:

Court actions/protests needed for final vs. protestable (180-day window) entries?

CAPE scope: Simple IEEPA refunds only, or complex EU/Japan agreements (15% caps), reconciliation, drawback?

Entry summary updates in ACE (system of record)? What if an entry’s accidentally omitted—does Treasury keep funds?

Judge indicated all IEEPA duties unlawful; no clear administrative refund mechanism yet.

Importers: Review internal processes against HQ 350722; consult brokers/attorneys on consultant/AI/OCR workflows.

Read CBP’s full ruling; track IEEPA CAPE mechanics and court filings.

Travel tip: Extra time for TSA lines. Watch petrodollar erosion and fuel surcharge ripple effects.

Credits

• YouTube

Join the conversation with fellow trade professionals in the Trade Geeks Community:

Hosts:  Andy Shiles & Lalo Solorzano

🧠 Episode Summary

In this episode of Simply Trade, we sit down with Vincent “Vinny” Annunziato for his first appearance post-retirement from U.S. Customs and Border Protection (CBP).

Vinny reflects on a remarkable career shaping some of the most impactful trade modernization efforts, including the Single Window initiative, and shares behind-the-scenes insights into how these systems were built, challenged, and ultimately delivered.

Now on the private sector side, Vinny discusses his transition, his new work with Profit Trust, and how companies can uncover hidden opportunities for duty recovery and cost savings.

The conversation also dives deep into AI in trade compliance, cutting through the hype to explain what actually works today—and what doesn’t. From large language models to human-assisted decision-making, Vinny brings a practical, no-nonsense perspective that trade professionals can immediately apply.

🔑 Key Learnings

💡 Key Takeaways

🔗 Resources & Mentions

🎧 Credits

Hosts:

Guest:

Producer:

📢 Subscribe & Follow

New episodes every week.

Presented by: Global Training Center — providing education, consulting, workshops, and compliance resources for trade professionals.

Connect with us:

Don’t forget to rate, review, and share with your fellow trade geeks!

Hosts: Renee Chiuchiarelli & Julie Parks

Renee and Julie break down how organizational structure—centralized, decentralized, matrix, or hybrid—directly impacts compliance success. Learn practical "tweaks" to move customs from a reactive support function to a proactive strategic partner.

1. Centralized Structure

The Issue: Customs reacts to problems after decisions are made.

The Fix: Embed controls upstream; ensure Customs has authority, not just execution duties.

💡 Truth Bomb: If you touch data after the PO is issued, you’re already too late.

2. Decentralized Structure

The Issue: Inconsistent data and fragmented processes across regions.

The Fix: Centralize governance and data visibility while allowing regional execution.

💡 Rule: Decentralized execution is fine; decentralized compliance is not.

3. Matrix Structure

The Issue: Decision gridlock and competing priorities.

The Fix: Define decision-making authority in writing and align funding across stakeholders.

💡 Reality Check: Without alignment, Customs becomes a referee, not a facilitator.

4. Hybrid Structure (The Goal)

The Issue: Often misperceived as a cost center rather than a value driver.

The Fix: Separate governance from operations; involve Customs in sourcing and risk-based audits.

Compliance fails in any structure when:

Authority doesn't match responsibility.

Brokers are treated as the "owners" of compliance.

Leadership only engages during a crisis.

Identify your current structure and pick one area for improvement. Write it into your goals and align it with business priorities to start seeing incremental change.

Hosts:

It’s a special Halloween edition of Simply Trade [Tips] with Hammer and Heels (Renee & Julie)! 🎙️

In this spooky seasonal episode, the hosts share “scary compliance stories” that every trade professional can learn from — tales of audits that wouldn’t die, supply chain skeletons, and hauntingly complex importer-of-record issues.

Between these frighteningly true stories and a fun “Trick-or-Treat: Fact or Fiction” lightning round, listeners will pick up valuable lessons about risk, recordkeeping, and compliance best practices — all while getting into the Halloween spirit.

Importer of Record Issues: Never assume your company should make entry — confirm the proper party has the right to do so.

Audit Nightmares: A prior disclosure can protect you from penalties, but only if it’s complete and accurate. Double-check everything before submitting.

Trick or Treat: Compliance Edition!

Can CBP review your General Ledger? ✅ Treat!

Do you need to reconcile quantity variances with Customs entries? ✅ Treat!

Is your broker solely responsible for recordkeeping? ❌ Trick! Importers must maintain their records for at least five years.

Is a parts database a strong compliance tool? ✅ Treat! It helps ensure data accuracy and consistency.

👉 This week’s action item:

Are your prior disclosures accurate and auditable?

Is your importer of record process clear?

Do your records meet the five-year rule?

And since it’s Halloween… figure out your costume, too! 🎭

Join the Trade Geeks Community at Global Training Center and share:

Your own “scary compliance story.”

How you’ve handled tricky audits or importer-of-record nightmares.

And, of course, what you’re dressing up as for Halloween!

Hosts:

Renee Chiuchiarelli

Julie Parks

Producer:

Lalo Solorzano

🎙️ New TIPS episodes every Tuesday.

Presented by: Global Training Center — providing education, consulting, workshops, and compliance resources for trade professionals.

Connect with us:

Simply Trade Podcast on LinkedIn

Global Training Center on LinkedIn

YouTube

Spotify

Apple Podcasts

Trade Geeks Community

Don’t forget to rate, review, and share with your fellow trade geeks!

📩 Want to be on the show or suggest a topic?

Host: Lori Mullins

Series: NCBFAA Quarterly Podcast – Transportation Committee Focus

NCBFAA Transportation Committee: Strait of Hormuz, FMC, and Shipping Risk in 2026

In this NCBFAA quarterly episode, social media director and licensed customs broker Lori Mullins sits down with Rich Roche, Senior Vice President at Mohawk Global Logistics and NCBFAA NVOCC Chair, and Ashley Craig, partner at Venable LLP and outside Transportation Counsel to NCBFAA, for a deep dive on the work of the NCBFAA Transportation Committee in a rapidly changing risk environment.​

The conversation focuses on how the Transportation Committee is engaging with regulators—especially the Federal Maritime Commission (FMC)—and monitoring global chokepoints like the Strait of Hormuz to protect brokers, forwarders, and NVOCCs.​

FMC leadership and priorities

Rich explains the “new season” at FMC under Chair Laura DiBella, with NCBFAA meeting her on day one and tracking the confirmation of additional commissioners to get the agency to full strength.​

The committee is watching FMC’s expanded role, including analyzing global “choke points” (like the Iran conflict and Spanish embargo actions) and supporting efforts to close the harbor maintenance fee loophole for cargo routed via Canada and Mexico.​

Strait of Hormuz and global chokepoints

Ashley breaks down why the Strait of Hormuz—only about 20 nautical miles wide and dominated geographically by Iran—remains one of the most critical choke points in global energy and trade, carrying roughly 60% of petroleum productsexiting the region.​

Rich details current impacts: hundreds of tankers and cargo vessels effectively stopped or trapped, export bookings halted, and knock-on effects on fuel availability for airlines and ocean carriers, particularly in Asia.​

Legal and commercial risk: surcharges, notice, and the Shipping Act

Ashley walks through how tensions translate into war risk surcharges and emergency contingency charges from major carriers (Maersk, CMA, Hapag-Lloyd, MSC, ONE), and the critical 30‑day notice requirement under the Shipping Act for U.S. trades—plus how “special permission” filings at the FMC can accelerate those timelines.​

The Transportation Committee is monitoring FMC guidance reminding carriers and NVOCCs of their obligations to publish and adhere to filed rates, and educating members on when to go to FMC vs. resolving disputes under service contracts or through courts/ADR.​

Export controls and NCBFAA’s export subcommittee work

Ashley highlights the work of the NCBFAA Export Subcommittee, which sits under the Transportation Committee and has collaborated with BIS on the Freight Forwarder Best Practices (now live on the BIS site).​

The committee is tracking evolving sanctions and export controls on Iran and third‑party intermediaries, stressing regular checks of the U.S. consolidated screening lists and ongoing engagement with BIS, OFAC, and other agencies.​

Insurance, force majeure, and contract readiness

From a legal and practical standpoint, Ashley urges members to review war risk underwriting, force majeure language, and service contracts now—especially for cargo stuck in the Gulf region—to avoid unmanaged detention/demurrage and misaligned risk allocation.​

The Transportation Committee is encouraging proactive dialogue with carriers and underwriters, not just reactive claims once disruptions surface.​

Energy markets, surcharges, and downstream costs

The episode covers how rising oil prices (already over USD 100/barrel with potential to go higher) drive up bunker costs, trigger higher bunker and emergency surcharges, and ultimately raise total transportation costs for shippers and NVOCC customers.​

Policy horizon: tariffs, ship taxes, and Jones Act talk

Ashley notes the administration’s heavy focus on maritime policy, new and potential 232/301 investigations, a 301 forced labor inquiry touching over 60 trading partners, and proposals like a “universal ship tax” and land border fee that NCBFAA and peer associations are actively reviewing.​

The committee is also watching discussions around Jones Act waivers for energy flows and coordinating with other trade associations (NITL, World Shipping Council, NRF, NAM, U.S. Chamber) to present a unified industry position.​

Throughout the episode, Lori, Rich, and Ashley underscore the resilience of the brokerage and forwarding community and the central role of NCBFAA—especially the Transportation Committee and its export subcommittee—in:

Interpreting fast‑moving developments at choke points like the Persian Gulf.

Engaging directly with FMC, BIS, Treasury, USTR, and Congress.

Providing practical guidance on surcharges, notice rules, contracts, underwriting, and compliance expectations.​

Lori closes by inviting non‑members to join NCBFAA and tap into its toolkits, best practices, and ongoing advocacy, and reminding listeners that this is part of a quarterly NCBFAA podcast series focused on the committees’ work on behalf of the trade.

Stay connected with the Simply Trade Podcast:

Global Training Center LinkedIn

YouTube

Spotify

Apple Podcasts

Trade Geeks Community

​

Host: Annik Sobing

Trade Jobs Are Exploding—But Here’s How to Actually Land One (Live from ICPA)

Live from ICPA, Annik sits down in-person with recruiting expert Colleen from Trade Compliance Recruiting Solutions—the boutique firm specializing exclusively in trade compliance roles (import/export, brokerage, analyst to VP). They break down the tight talent market, entry-level realities, resume pitfalls, salary trends, and why busy pros aren’t jumping ship lightly. If you’re job hunting, hiring, or just curious about trade career paths—this is your roadmap.

Credits

Listen & Subscribe

Connect with Simply Trade

Join the Trade Geeks Community

Host: Cindy Allen

In this week’s episode of Simply Trade: Cindy’s Version, Cindy Allen breaks down the latest developments following the Supreme Court’s decision striking down IEEPA tariffs—and what CBP is proposing as a path forward for duty refunds.

CBP has introduced a proposed automated system called CAPE (Consolidated Administration Processing of Entries) to manage refund claims tied to the invalidated tariffs. While the proposal answers some questions, it also raises several new operational considerations for importers and customs brokers.

At the same time, global trade policy continues to move quickly. The administration has launched new Section 301 investigations covering 16 major economies, announced forced labor investigations involving 60 countries, and is monitoring supply chain risks tied to oil disruptions in the Strait of Hormuz.

Inspired by Taylor Swift’s This Is Me Trying, Cindy walks through what we know, what we don’t know yet, and why the trade community may need to remain patient as the refund process takes shape.

• New Section 301 investigations targeting structural excess manufacturing capacity across 16 economies

Following the Supreme Court decision, CBP has proposed a new automated refund system called CAPE, which would allow importers or brokers to submit claims through a portal connected to ACE.

The proposal includes:

• A portal-based refund submission process

While the framework is promising, several operational questions remain—including how already liquidated entries, reconciliation filings, and broker system updates will be handled.

• CBP is developing a structured process for IEEPA duty refunds

Host:

Producer:

Simply Trade is produced by

• YouTube

Join the conversation with fellow trade professionals in the Trade Geeks Community:

Simply Trade Podcast

Host: Lalo Solorzano

In this episode of Simply Trade, Lalo Solorzano sits down with Cindy Deleon and John Metrich from Deleon Trade to explore one of the more complex corners of trade compliance: advanced Section 232 tariff enforcement and metal value content analysis.

Recorded shortly after the Advanced Topics in Customs Compliance Conference (ATCC), the conversation dives into how trade professionals are navigating the increasingly sophisticated enforcement environment surrounding Section 232 tariffs.

Cindy and John share insights from their work helping companies analyze metal value content, prepare for potential enforcement actions, and think strategically about how these tariffs are being applied in practice. The discussion highlights why Section 232 compliance is no longer just a basic classification issue but often requires deeper operational and sourcing analysis.

For trade professionals dealing with steel, aluminum, derivative products, or complex supply chains, this episode provides a valuable look into the advanced compliance considerations shaping today’s trade environment.

The purpose and structure of the Advanced Topics in Customs Compliance Conference (ATCC)

Why Section 232 compliance has become increasingly complex

How metal value content calculations are impacting imports

Enforcement trends and what regulators are focusing on

The importance of understanding supply chain inputs and sourcing

How companies should prepare for deeper scrutiny and potential audits

Practical insights from working with importers facing these challenges

1. Section 232 compliance goes far beyond classification

2. Enforcement is becoming more sophisticated

3. Advanced knowledge matters

4. Education and collaboration are critical

Cindy Deleon – https://www.linkedin.com/in/cindydeleon/

John Metrich – https://www.linkedin.com/in/john-metrich-3b896a53/

Deleon Trade – https://www.deleontrade.com

Advanced Topics in Customs Compliance Conference (ATCC) – https://www.customsconferences.com/

Learn more about trade compliance training – https://www.globaltrainingcenter.com

Host:

Guests:

Producer:

Podcast:

Stay connected with the Simply Trade Podcast:

Global Training Center LinkedIn

YouTube

Spotify

Apple Podcasts

Trade Geeks Community

What are you seeing with Section 232 enforcement and metal value content requirements?

Share your thoughts and experiences with the trade community and join the discussion.