Global vs US vs Regional Trade Compliance: A RACI Matrix Template for Org Design
How do you split trade compliance responsibilities across Global, US, and Regional teams? RACI matrix template covering classification, valuation, FTA, audits, and policy.
Co-Founder of GingerControl, Building scalable AI and automated workflows for trade compliance teams.
Connect with me on LinkedIn! I want to help you :)How do you split trade compliance responsibilities across Global, US, and Regional teams?
A clean RACI (Responsible, Accountable, Consulted, Informed) matrix that maps each compliance activity to the right team layer. Global typically owns policy strategy, multi-region program design, and consolidated reporting. US owns U.S. import/export compliance, ACE filing oversight, CBP audit response, and U.S.-specific regulatory monitoring. Regional owns local country compliance (Mexico, Canada, EU, Asia-Pacific), local language coordination, and regional broker management. The right split depends on company structure, regional volumes, and product complexity, but the RACI framework is the same.
What activities actually need a RACI assignment?
Twelve compliance activity clusters typically need explicit RACI assignment: HS/HTS classification, customs valuation, country of origin determination, FTA qualification, denied party screening, export licensing, ACE filing and entry oversight, broker management, audit response (CF-28/CF-29, Focused Assessment), reasonable care documentation, policy monitoring and change management, and compliance reporting. Without explicit RACI, common failure modes include shared accountability (nobody actually owns it), gaps where activities are not assigned, or duplication where multiple teams do overlapping work without coordination.
TL;DR: Global trade compliance organizations split work across Global, US, and Regional teams in patterns that vary by company structure but follow common principles. A RACI matrix makes the split explicit per activity, prevents accountability gaps and duplication, and supports the audit-defense documentation that CBP and equivalent foreign authorities evaluate during compliance reviews. This guide provides a template RACI matrix covering 12 compliance activity clusters, with notes on common variations by company structure (single US-import, multi-region operating, global manufacturing). For Chinese-origin importers operating across Chinese HQ, Mexico nearshoring, and US filing, the RACI matrix maps cleanly to the multilingual coordination work that GingerControl's team supports natively. For US-only importers, the matrix reduces to a simpler split between Global (policy, monitoring) and US (execution). GingerControl's compliance audit service supports compliance program design including RACI definition, gap analysis, and ongoing program operation. CBP collected $225.8 billion in duties, taxes, and fees in FY 2025, with audit-related revenue at $117.67 million across 417 FY 2025 audits, reinforcing why clear accountability matters for audit defense.
Last updated: May 2026
Why RACI Matters for Trade Compliance
Trade compliance activities frequently fall through the cracks when accountability is shared or unstated. The common failure modes:
Shared accountability without ownership. "The compliance team handles classification" sounds clear until two teams (Global and US) each think the other is doing it. When a CF-28 arrives, the response work starts late because ownership has to be sorted before substantive work can begin.
Gaps where activities are not assigned. "Who tracks Section 122 changes affecting our catalog?" If no team explicitly owns policy monitoring, the answer is often "we should have someone doing that" after a missed change has already affected cost.
Duplication without coordination. Both Global and US teams may classify the same products to different codes because they apply different reasoning. When CBP compares the two classifications during audit, the inconsistency itself becomes a finding.
A RACI matrix prevents all three by explicitly assigning Responsible, Accountable, Consulted, and Informed roles per activity. The roles:
- Responsible (R): Does the work
- Accountable (A): Owns the outcome, signs off on the work
- Consulted (C): Provides input before the work is done
- Informed (I): Receives notification after the work is done
Each activity has exactly one Accountable (single point of ownership) and may have multiple Responsible, Consulted, and Informed roles.
The Template RACI Matrix
The following matrix covers 12 compliance activity clusters with a typical assignment across Global, US, and Regional teams. Adjust for your specific organization.
1. HS/HTS Classification
| Activity | Global | US | Regional |
|---|---|---|---|
| Classification policy and standards | A | R | C |
| Initial classification of new products | I | R / A (US imports) | R / A (regional imports) |
| Classification dispute resolution | C | R / A (US) | R / A (regional) |
| Classification documentation retention | I | R / A (US) | R / A (regional) |
Notes: Classification operates close to filing, so US team typically owns US imports and Regional teams own their respective imports. Global sets standards and approves cross-region consistency.
2. Customs Valuation
| Activity | Global | US | Regional |
|---|---|---|---|
| Transfer pricing strategy | A | C | C |
| Valuation methodology per entry | I | R / A (US) | R / A (regional) |
| Reconciliation entry filing | I | R / A (US) | R / A (regional) |
| Assist, royalty, addition value documentation | C | R / A (US) | R / A (regional) |
Notes: Valuation often connects to corporate tax (transfer pricing); Global typically holds the policy with regional execution.
3. Country of Origin Determination
| Activity | Global | US | Regional |
|---|---|---|---|
| Substantial transformation policy | A | C | C |
| Per-product country of origin determination | I | R / A (US) | R / A (regional) |
| Country-of-melt tracking (Section 232) | C | R / A (US) | R / A (regional sourcing) |
| Origin documentation retention | I | R / A (US) | R / A (regional) |
4. FTA Qualification
| Activity | Global | US | Regional |
|---|---|---|---|
| FTA strategy and prioritization | A | R | R |
| USMCA, KORUS, CBI, GSP qualification | C | R / A (US imports) | R / A (regional exports/imports) |
| Certificate of Origin issuance | I | R / A (US-bound) | R / A (regional) |
| Vendor CoO collection | C | R / A (US) | R / A (regional) |
5. Denied Party Screening
| Activity | Global | US | Regional |
|---|---|---|---|
| Screening tool selection and policy | A | C | C |
| Per-transaction screening | I | R / A (US transactions) | R / A (regional transactions) |
| Hit review and escalation | C | R / A | R / A |
| Screening documentation retention | I | R / A | R / A |
6. Export Licensing
| Activity | Global | US | Regional |
|---|---|---|---|
| Export controls policy (EAR, ITAR equivalents) | A | R | R |
| ECCN classification | C | R / A (US exports) | R / A (regional exports) |
| BIS license application (SNAP-R) | I | R / A (US-origin) | C |
| License compliance and recordkeeping | I | R / A (US) | R / A (regional) |
7. ACE Filing and Entry Oversight
| Activity | Global | US | Regional |
|---|---|---|---|
| ACE access and POA management | I | R / A | C |
| Entry summary review | I | R / A | N/A |
| Liquidation tracking | I | R / A | N/A |
| Form 4811 and sub-account management | I | R / A | N/A |
Notes: ACE is U.S.-specific so the US team owns operationally. Global is informed for reporting.
8. Customs Broker Management
| Activity | Global | US | Regional |
|---|---|---|---|
| Broker selection and contracting | C | R / A (US brokers) | R / A (regional brokers) |
| Broker performance review | C | R / A (US) | R / A (regional) |
| Broker error and dispute management | C | R / A (US) | R / A (regional) |
9. Audit Response
| Activity | Global | US | Regional |
|---|---|---|---|
| Audit response strategy and framework | A | R | R |
| CF-28 / CF-29 response (US) | C | R / A | N/A |
| Focused Assessment response (US) | C | R / A | C |
| Foreign customs audit response | C | C | R / A (per country) |
| Audit finding remediation | A | R (US) | R (regional) |
10. Reasonable Care Documentation
| Activity | Global | US | Regional |
|---|---|---|---|
| Reasonable care program policy | A | R | R |
| Per-entry reasoning chain documentation | I | R / A (US) | R / A (regional) |
| Periodic classification review | C | R / A (US) | R / A (regional) |
| Reasonable care audit trail retention | I | R / A | R / A |
11. Policy Monitoring and Change Management
| Activity | Global | US | Regional |
|---|---|---|---|
| Section 301 / 232 / 122 / Chapter 99 monitoring | A | R | C |
| USMCA, FTA, regional trade agreement monitoring | A | R | R |
| HTS schedule update tracking | C | R / A (US) | R / A (regional) |
| Policy change impact assessment | A | R | R |
Notes: Compliance Radar supports the policy monitoring activity with personalized alerts matched to the importer's catalog.
12. Compliance Reporting
| Activity | Global | US | Regional |
|---|---|---|---|
| Compliance KPI definition | A | C | C |
| US compliance metrics | I | R / A | N/A |
| Regional compliance metrics | I | N/A | R / A |
| Consolidated global reporting | R / A | C | C |
| Board / leadership reporting | A | R | R |
Common Variations by Company Structure
Variation 1: US-Only Importer
For companies with only U.S. import activity, the matrix simplifies. Global becomes "Corporate" (sets policy) and US becomes "Operations" (executes). Regional roles do not apply.
Variation 2: Multi-Region Operating Company
For companies with import operations in multiple regions, the matrix expands. Regional roles are split across each operating region (US, EU, APAC, LATAM) with consistent activities per region.
Variation 3: Global Manufacturer with Multi-Country Origin
For Chinese-origin manufacturers operating Mexico nearshoring with US import filing, the matrix involves three operational geographies (Chinese HQ, Mexico operations, US filing). The Regional row in the template above can be split into "Mexico" and "China" rows to reflect this structure. GingerControl's multilingual team support (Mandarin, Cantonese, Spanish, English) aligns with this structure natively.
Variation 4: SMB with Limited Compliance Team
For smaller companies, multiple activities may consolidate to a single team. The RACI matrix is still useful for surfacing what is unassigned, even if the assignment is "external counsel" or "customs broker" rather than internal team.
How to Use the Matrix in Your Organization
Five practical steps:
Step 1: Map your current state. Use the template to map which team currently performs each activity. Identify gaps (activities with no clear owner) and overlaps (activities with multiple Accountables).
Step 2: Resolve gaps and overlaps. For each gap, assign accountability. For each overlap, designate the single Accountable team. The goal is exactly one Accountable per activity.
Step 3: Document the matrix in your compliance program manual. The RACI becomes part of your reasonable care documentation. CBP and equivalent foreign authorities evaluate compliance programs during audits; an explicit RACI is favorable evidence.
Step 4: Communicate to affected teams. Each team should know what they are Accountable, Responsible, Consulted, and Informed for. Periodic review (annually at minimum) keeps the matrix current as the organization evolves.
Step 5: Update as the organization changes. New product lines, new regions, new regulations, and team restructuring all affect the matrix. Treat it as a living document, not a one-time exercise.
Frequently Asked Questions
What is a RACI matrix?
A RACI matrix maps responsibilities across activities and teams using four roles: Responsible (does the work), Accountable (owns the outcome), Consulted (provides input), and Informed (receives notification). Each activity has exactly one Accountable to ensure clear ownership.
Why does trade compliance specifically need a RACI?
Trade compliance involves cross-functional work (classification, valuation, broker management, audit response) that often spans multiple teams. Without explicit RACI, common failure modes include shared accountability without ownership, gaps where activities are not assigned, and duplication where multiple teams do overlapping work.
How often should the RACI be updated?
At minimum annually. Major organizational changes (new region, new product line, team restructuring, regulation changes) should also trigger a review. Treat the RACI as a living document.
Does the RACI matrix replace job descriptions?
No. The RACI is a cross-functional view of who does what across activities. Job descriptions still define individual roles and responsibilities. The RACI shows how individual roles connect across the compliance program.
How does GingerControl support compliance program design?
GingerControl's compliance audit service supports compliance program design including RACI definition, gap analysis, ongoing program operation, and audit defense documentation. The work is conducted by the trade compliance team and can be conducted in Mandarin, Cantonese, Spanish, or English depending on the team's preference.
What is the most commonly missing role in trade compliance RACIs?
Policy monitoring and change management. Many compliance programs do not explicitly assign accountability for tracking Section 301, Section 232, Section 122, USMCA, and other policy changes. The result is missed changes that affect cost or compliance until discovered through audit or financial review. Compliance Radar fills this gap with personalized policy alerts.
How do I handle activities that span Global, US, and Regional teams?
Pick one Accountable team based on where the work most naturally sits. For activities that span operational boundaries (like FTA qualification that involves both US import and regional sourcing), the Accountable is typically the team closest to the filing or transaction; the other team is Responsible for upstream inputs.
Should external parties (brokers, counsel) appear in the RACI?
Yes. For activities where external parties perform substantial work (broker entry filing, counsel-led audit defense), the external party should appear as Responsible with internal team as Accountable. This makes the role of external parties explicit and prevents accountability gaps when external work is incomplete.
Design Your Trade Compliance RACI
If your trade compliance program does not have an explicit RACI matrix, the work of building one surfaces gaps and overlaps that affect audit defense, cost management, and operational efficiency. The template above is a starting point; the specific assignment depends on your organization structure, regional volumes, and product complexity.
Get a compliance program review from GingerControl. The review evaluates your current compliance program including RACI definition, identifies gaps and overlaps, and recommends program design changes. The quick compliance quiz identifies the highest-priority gaps before scoping deeper review.
GingerControl is not just a tool. Our team includes native Mandarin, Cantonese, Spanish, and English speakers who support compliance program design across multilingual operational structures (Chinese HQ, Mexico nearshoring, US filing). Talk to our team about your trade compliance program design.
References
[REF 1] CBP Informed Compliance Publication, Reasonable Care Data cited: Reasonable care standard requiring documented procedures Source: CBP Reasonable Care Publication Published: September 2017
[REF 2] U.S. Customs and Border Protection, Trade Statistics Data cited: $225.8 billion in duties, taxes, and fees collected in FY 2025 Source: CBP Trade Statistics Published: 2025
[REF 3] CBP Quick Response Audits, FY 2025 Audit Statistics Data cited: 417 audits completed, $117.67 million in audit-related revenue Source: CBP Quick Response Audits Published: 2025
[REF 4] CBP Focused Assessment Program Data cited: Audit methodology evaluating compliance program controls Source: CBP Focused Assessment
[REF 5] 19 U.S.C. 1484, Reasonable Care Data cited: Importer reasonable care obligation Source: 19 U.S.C. 1484
[REF 6] USMCA, KORUS, CAFTA-DR, and Other FTA Implementation Data cited: FTA qualification activities requiring RACI coverage Source: USTR Free Trade Agreements
Written by
Chen Cui
Co-Founder of GingerControl
Building scalable AI and automated workflows for trade compliance teams.
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