[TIPS] Recordkeeping — An Easy Compliance Win You Can’t Afford to Ignore

Host: Lalo Solorzano
Guest(s): Arthur O’Meara
Published: September 22,2026
Length: ~8 minutes
Presented by: Global Training Center

Recordkeeping may not be the most exciting part of trade compliance, but Arthur O’Meara has one word for what can happen when companies get it wrong: draconian.

In Episode 3 of this Simply Trade Tips series, host Lalo Solorzano and Arthur tackle an often-overlooked part of import compliance: keeping the records you may need when Customs comes asking. Arthur explains why the A1A recordkeeping list can initially seem intimidating—and why compliance doesn't necessarily mean copying every document into one massive entry file. Instead, companies should understand what records are required, know exactly where those records are maintained, and periodically verify that they remain accessible.

The conversation also addresses a practical challenge facing trade professionals: when tariffs, classification changes, and other urgent issues consume your time, routine compliance tasks can slip down the priority list.

Arthur's recommendation? Make recordkeeping part of your annual compliance goals. It's a manageable exercise that can help protect the company before a CBP request puts your records to the test.

This episode focuses on establishing a practical and sustainable approach to trade recordkeeping.

Arthur explains that companies don't necessarily need to duplicate every required document and store everything alongside their entry records. Using purchase orders as an example, he suggests documenting where the records are maintained—such as within purchasing or procurement—and periodically confirming that the responsible department continues to retain them.

The important question is whether the company can produce the required records when they're requested.

Arthur also discusses what can happen when CBP sends a CBP Form 28 Request for Information. At that point, the trade compliance professional may suddenly need to locate marketing literature, transaction documentation, or other records while working against a response deadline.

His preferred approach is proactive: periodically review the company's recordkeeping practices before a government request arrives.

• Don't let the A1A list overwhelm you: Understand which records actually apply to your transactions rather than assuming every item on the list belongs in every file.

• Know where your records live: A document doesn't necessarily have to be duplicated into one centralized file if you can identify where it's maintained and retrieve it when necessary.

• Periodically verify accessibility: Don't assume another department is still retaining a record simply because it was there the last time you checked.

• Prepare before a CBP Form 28 arrives: A request for information is not the ideal time to discover gaps in your recordkeeping process.

• Make recordkeeping an annual goal: Arthur describes it as an “easy win” that doesn't have to consume significant time but can help protect the company.

• Global Training Center

• Lalo Solorzano

Guest(s):
Arthur O’Meara - LinkedIn

Producer:
Lalo Solorzano

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