Global vs US vs Regional Trade Compliance: A RACI Matrix Template for Org Design

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.

Use denied-party and sanctions screening program design to set the screening cadence, escalation rules and evidence trail.

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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 301 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

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

Notes: Valuation often connects to corporate tax (transfer pricing); Global typically holds the policy with regional execution.

3. Country of Origin Determination

4. FTA Qualification

5. Denied Party Screening

6. Export Licensing

7. ACE Filing and Entry Oversight

Notes: ACE is U.S.-specific so the US team owns operationally. Global is informed for reporting.

8. Customs Broker Management

9. Audit Response

10. Reasonable Care Documentation

11. Policy Monitoring and Change Management

Notes: Compliance Radar supports the policy monitoring activity with personalized alerts matched to the importer's catalog.

12. Compliance Reporting

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.

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 trade advisory, quoted for its scope, helps build compliance SOPs, including who owns each activity, as a second pair of eyes, and its compliance audit, a paid 30-minute review, shows where your entities, brokers and records disagree.

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, 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.

Build monitoring Section 301 list changes around the approved HTS codes that determine each product's list assignment.

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.

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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.

Talk to our team about your trade compliance program design.

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References

1. CBP Informed Compliance Publication, Reasonable Care
   Data cited: Reasonable care standard requiring documented procedures
   Source: CBP Reasonable Care Publication
   Published: September 2017
2. U.S. Customs and Border Protection, Trade Statistics
   Data cited: $216.7 billion in duties, taxes, and fees collected in FY 2025
   Source: CBP Trade Statistics
   Published: 2025
3. U.S. Customs and Border Protection, Trade Statistics, FY 2025 audits
   Data cited: 465 audits completed, $235.47 million collected as a result of importer audits
   Source: CBP Trade Statistics
   Published: 2025
4. CBP Focused Assessment Program
   Data cited: Audit methodology evaluating compliance program controls
   Source: CBP Focused Assessment
5. 19 U.S.C. 1484, Reasonable Care
   Data cited: Importer reasonable care obligation
   Source: 19 U.S.C. 1484
6. USMCA, KORUS, CAFTA-DR, and Other FTA Implementation
   Data cited: FTA qualification activities requiring RACI coverage
   Source: USTR Free Trade Agreements