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

Hosts: Renee Chiuchiarelli & Julie Parks
Length: ~15 minutes
Format: Simply Trade Tips

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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.

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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.

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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.

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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.

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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.

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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.

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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.

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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.

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This Episode’s FIO (Figure It Out)

Take a hard look at your organization:

1. Which structure are you operating in — centralized, decentralized, or matrix?

2. What’s working well?

3. Where are the structural gaps?

4. 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.

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Join the Conversation

Where does Customs sit in your organization?

And more importantly — is it positioned for influence or just paperwork?

Let us know inside the Trade Geeks Community or connect with us on LinkedIn.

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Credits

Hosts:
Renee Chiuchiarelli
Julie Parks

Producer:
Lalo Solorzano

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

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