Where Does Customs Belong? Org Structures That Make (or Break) Compliance

Hosts: Renee Chiuchiarelli & Julie Parks Length: ~15 minutes Format: Simply Trade Tips Episode Summary Welcome to Series 6 of Simply Trade Tips. This series tackles a foundational — and often overlooked — issue in global trade: Where does Customs actually sit inside your organization? In this opening episode, Renee and Julie lay the groundwork by breaking down the three most common organizational structures and how each one impacts customs operations, compliance authority, budgeting, and risk management. Because here’s the truth: Customs rarely fails because people don’t care. It fails because it’s structurally misaligned. This episode sets the foundation for understanding how org structure dictates decision-making, funding, escalation paths, and ultimately — compliance outcomes. Why Org Structure Matters for Customs Customs sits in the middle of everything: Procurement Finance Logistics Legal Tax Sales & contracts Export operations Yet it rarely “owns” all the decisions that affect it. That misalignment can create compliance gaps, conflicting priorities, and operational tension between speed and governance. Follow the money. Follow the reporting lines. That’s where risk lives. The Three Core Organizational Structures 1️⃣ Centralized (Functional) Structure Definition: Departments operate in defined lanes (Supply Chain, Finance, Legal, Sales), each with its own leadership. Where Customs Usually Sits: Under Supply Chain Under Legal Occasionally under a dedicated Trade Compliance function Upside: Clear ownership Defined reporting line Often its own budget (if structured well) Downside: Under Supply Chain → can become overly execution-focused (velocity & cost driven) Under Legal → can become overly compliance-focused and disconnected from operations If no independent budget → strategy becomes fragmented Key theme: Budget authority drives strategic control. 2️⃣ Decentralized (Divisional) Structure Definition: Trade responsibilities are spread across business units, regions, or product lines. Each division may manage its own customs activity. Upside: Faster decision-making Direct access to business leaders Local agility Downside: Inconsistent processes across divisions Requires corporate oversight or council to maintain standards Heavy reliance on influence rather than authority This model works — but it requires strong coordination and governance discipline. 3️⃣ Matrix (Hybrid) Structure Definition: Dual reporting lines — often operationally to Supply Chain, dotted line to Legal, Tax, or Finance. This is where many global organizations land. Reality of the Matrix: Multiple “bosses” Consensus-driven decisions Speed vs. compliance tension Performance reviews may not align with dotted-line accountability Success in a matrix requires: Clear budget ownership Clear escalation paths Strong consensus-building skills Mature leadership alignment Without alignment, it becomes a tug-of-war between execution and governance. Customs Operations vs. Customs Compliance A critical distinction discussed in this episode: Customs Operations: Entry filings ACE submissions Broker management Day-to-day problem solving Customs Compliance: Classification governance Valuation methodology Origin policy Audit strategy Risk tolerance Julie and Renee strongly advocate for structural separation of these roles — even in small teams. Why? Operations finds errors. Compliance fixes root causes. Both must cross-communicate consistently. When they don’t align, friction, inefficiency, and risk increase. Real-World Red Flags Renee and Julie call out four common structural warning signs: 🚩 1. Customs buried too deep Under logistics, contracts, or sales without escalation authority. 🚩 2. Broker “owns” compliance Brokers file entries — they do not own your risk. 🚩 3. No executive sponsor A sponsor is not a cheerleader — it’s a leader who clears roadblocks and escalates risk appropriately. 🚩 4. Customs is not the budget holder If you don’t control funding, you don’t control strategy. The Big Takeaway There is no “perfect” structure. Centralized, decentralized, and matrix models can all work. But maturity shows up in: Clear decision rights Budget authority Executive sponsorship Alignment between operations and compliance Structure doesn’t eliminate risk. Misalignment creates it. This Episode’s FIO (Figure It Out) Take a hard look at your organization: Which structure are you operating in — centralized, decentralized, or matrix? What’s working well? Where are the structural gaps? Who holds the budget and escalation authority? Because you can’t fix what you haven’t identified. Future episodes in this series will focus on how to modernize or optimize each model — whether through small tweaks or major reorgs. Join the Conversation Where does Customs sit in your organization? And more importantly — is it ...