Simply Trade

Host: Cindy Allen
Guest(s): N/A
Published: November 6, 2026
Length: ~28 min.
Presented by: Global Training Center

Summary
Could a company with U.S. operations still face foreign importer of record requirements—and what would that mean for its customs broker? In this episode of Simply Trade: Cindy’s Version, Cindy Allen uses Taylor Swift’s “I Knew You Were Trouble” to explore the risks hiding behind familiar client relationships.

Cindy examines the interim final rule on heightened requirements for foreign importers of record, focusing on the questions it raises about U.S. importer status, beneficial ownership, documentation, and CTPAT participation. She discusses why publicly traded companies, foreign-owned manufacturers, and customs brokers need to look closely at how the requirements apply to their businesses. She also considers the potential impact on express shipments and the responsibilities a broker takes on when serving as importer of record.

Before the main discussion, Cindy shares her post-election tariff outlook and updates on demurrage and detention, ACE client support, USMCA negotiations, and customs enforcement.

Her central message: understand your data, respond to CBP, and provide practical feedback. For importers and brokers navigating an uncertain compliance environment, this conversation offers important questions to ask before a client’s trouble becomes your own.

This Week in Trade
• Tariffs after the midterms: Cindy shares her outlook on congressional oversight, possible targeted changes, and why she does not expect a sweeping tariff repeal.

• FMC and ACE developments: Cindy highlights a demurrage and detention symposium and a test program intended to improve connections between the trade community and ACE client representatives.

• USMCA negotiations: Cindy discusses Canada’s negotiating stance and what it could mean for conversations with the United States.

• CBP enforcement: Cindy cites reported increases of 77.5% in overall enforcement and 124% in Form 29 notices, emphasizing the importance of understanding import data and responding to customs inquiries.

Main Topic / Discussion
The main discussion centers on how heightened foreign importer of record requirements could reshape client verification and risk management for customs brokers. Cindy examines the ownership and real-property criteria used to distinguish U.S. and foreign importers, the documentation brokers would need to review, and CTPAT’s role in the entry process.

She raises practical questions about proving beneficial ownership for publicly traded companies, evaluating foreign-owned businesses with substantial U.S. operations, and handling powers of attorney when a broker acts as importer of record. She also considers whether increased demand for eligible brokers could create capacity challenges.

For Cindy, the issue extends beyond paperwork: who can produce the required information, who can verify it, what will it cost, and who carries the liability? She urges businesses to give CBP concrete examples and realistic cost estimates, either directly or through their trade associations.

Key Takeaways
• Revisit importer status. Cindy cautions against assuming that U.S. incorporation or a domestic address alone resolves the question of whether a company qualifies as a U.S. importer of record.

• Make client verification a risk decision. Ownership records, supporting documentation, CTPAT status, and potential importer-of-record responsibilities belong in the onboarding conversation.

• Know your data and engage with CBP. Cindy emphasizes responding to Forms 28 and 29 and seeking clarification when an action appears inconsistent with your records.

• Make regulatory feedback specific. Use business examples, supporting facts, and realistic cost estimates to explain implementation challenges—not simply that compliance will be difficult.

Resources & Mentions
• Global Training Center

• Heightened Requirements for Foreign Importers of Record — Official Federal Register Rule GovInfo

• Kelley Drye — Monitoring CBP’s Implementation of EO 14411 Kelley Drye & Warren LLP

• Episode inspiration: “I Knew You Were Trouble” by Taylor Swift, from Red.

Credits
Host:
Cindy Allen

Guest(s):
N/A

Producer:
Lalo Solorzano

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Host:
Lalo Solorzano
Andy Shiles

Guest(s): Justin Dillon
Published: November 4, 2028
Length: Approximately 41 minutes
Presented by: Global Training Center

Summary
Could your company be connected to forced labor without knowing it? In this episode of Simply Trade, hosts Lalo Solorzano and Andy Shiles welcome Justin Dillon, founder of FRDM, for a conversation about the people behind the products—and the responsibilities that come with buying, sourcing, and importing them.

Justin explains how forced labor concerns have moved from corporate philanthropy into sourcing, trade compliance, and business operations. Together, they explore what importers should consider before selecting suppliers, why procurement and compliance teams need to work together, and how supply chain visibility can help companies ask better questions before goods reach the border.

The discussion also goes beyond policies and paperwork. Justin shares the experiences behind his documentary work and advocacy, discusses FRDM’s relationship with WiseTech Global, and points listeners toward organizations supporting people affected by exploitation.

At the center of the episode is a compelling idea: meaningful change does not have to depend on a special campaign or a charitable budget. It can begin with everyday purchasing decisions. For trade professionals and business leaders, this conversation offers a reason to look more closely at where products come from—and what responsible sourcing should look like in practice.

Main Topic / Discussion
Responsible sourcing starts before supplier selection
Justin traces the shift from corporate social responsibility initiatives to supply chain due diligence and import enforcement. The discussion emphasizes early supplier vetting and collaboration among purchasing, trade compliance, legal, operations, and leadership—not waiting until a shipment encounters problems at the border.

Awareness, exploitation, and meaningful action
Justin shares the context behind the rescue footage discussed in the episode and explains why recognizing exploitation is not always straightforward. Rather than encouraging listeners to conduct their own investigations, the conversation focuses on transparency, established reporting channels, and supporting local organizations already doing the work.

Making human rights part of everyday business
Justin challenges reliance on supplier questionnaires and one-time audits, advocating instead for data- and AI-driven supply chain mapping followed by deeper supplier participation. He also discusses FRDM and WiseTech Global, the influence of procurement spending, and his goal of making human rights a routine business consideration rather than an occasional campaign.

Key Takeaways
• Start before onboarding. Evaluate supply chain risks before committing to suppliers, when changing direction is less disruptive.

• Bring the right teams together. Responsible sourcing requires coordination across procurement, compliance, legal, operations, and executive leadership.

• Look beyond the first supplier relationship. Justin advocates mapping supply chains and asking suppliers to extend that visibility through their own networks.

• Put purchasing power to work. Align supplier expectations with company values, while supporting established organizations and reporting channels when concerns arise.

Resources & Mentions
Guest, organizations, and technology
• Global Training Center — Presenter of Simply Trade and trade compliance education resources.

• Justin Dillon on LinkedIn — Connect with this episode’s guest.

• FRDM — The supply chain risk, mapping, and compliance technology discussed by Justin. frdm.ai

• WiseTech Global — The company discussed in connection with FRDM’s expansion.

• WiseTech Global’s FRDM acquisition announcement — Official background on the transaction discussed in the interview. wisetechglobal.com

• Made in a Free World — The nonprofit Justin recommends for supporting projects that help rescue and care for people affected by slavery and exploitation. madeinafreeworld.com

Documentary and additional videos
• Call & Response — Full Documentary — The full documentary link supplied for this episode. YouTube

• FRDM YouTube Channel — Additional videos from FRDM.

• Justin Dillon on CNN’s Quest Means Business — The additional interview supplied for this episode. YouTube

Help and reporting
• National Human Trafficking Hotline — In the United States, call 1-888-373-7888 or text 233733 (BEFREE) for assistance or to report a potential trafficking situation. For immediate danger, call 911. National Human Trafficking Hotline

Official background on the laws and enforcement topics discussed
These links provide additional reference material; not every resource below was named individually during the conversation.

• U.S. Customs and Border Protection — Forced Labor — Official starting point for forced-labor enforcement information and importer resources. GovDelivery

• CBP — Uyghur Forced Labor Prevention Act Overview — Background on the UFLPA and its import restrictions. CBP Help

• European Commission — Forced Labour Regulation — Official information on the EU framework. The product prohibition applies from December 14, 2027. single-market-economy.ec.europa.eu

• UK Government — Transparency in Supply Chains: A Practical Guide — Modern slavery reporting and supply chain transparency guidance for businesses. GOV.UK

• Australian Government — Modern Slavery Act — Official background on Australia’s modern slavery reporting framework. Attorney-General's Department

• Public Safety Canada — Forced Labour in Canadian Supply Chains — Guidance and reporting resources under Canada’s Supply Chains Act. Public Safety Canada

• Canada Border Services Agency — Goods Manufactured or Produced by Prison or Forced Labour — Background on Canada’s import prohibition. Canada Border Services Agency

• Mexico’s STPS — Forced Labor Import Restrictions — Official information on Mexico’s mechanism for investigating and restricting imports produced with forced labor. Resource in Spanish. Trabajo Forzoso

Additional practical reporting resource
• CBP Forced Labor Allegation Portal — An additional resource, not named in the episode, for submitting allegations involving forced labor in imported goods. GovDelivery

Other organizations mentioned in passing
These organizations came up during the discussion of corporate volunteering, philanthropy, and business models; they were not presented as trafficking-response resources.

• Habitat for Humanity — Referenced by Andy as an example of organized corporate volunteering.

• Anthropic — Mentioned briefly by Justin during the discussion of philanthropy and business models.

The individual local organizations described in India and Ghana were not identified by name in the transcript.

Credits
Host:
Lalo Solorzano
Andy Shiles

Guest(s):
Justin Dillon - LinkedIn

Producer:
Lalo Solorzano

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Host: Lalo Solorzano
Guest(s): Miriam Name, Cacheaux, Cavazos & Newton (CCN)
Published: November 3, 2027
Length: ~16 min
Presented by: Global Training Center

Summary
Your Mexican customer asks for a purchase agreement—even though you have been doing business for years using purchase orders and invoices. Why the extra paperwork?

In Episode 5 of 90 Days Until 2027, Lalo Solorzano welcomes back Miriam Name to explore how U.S. exporters can support their Mexican customers’ compliance efforts. After a lighthearted Día de los Muertos opening, the conversation turns to a serious question: can the importer document what happened throughout the transaction and support the value declared?

Miriam discusses purchase-agreement requests that are catching some U.S. sellers off guard, the commercial details those agreements should address, and the complications that rebates and deductions can create. Lalo also asks how the documentation changes when the relationship involves manufacturing services or a sale between related companies.

The goal is not to turn every request into a renegotiation of an established business relationship. Miriam offers a practical approach for connecting existing purchase orders, commercial documents, and terms through a master agreement.

This week’s tip puts cooperation first. Before treating a request as unnecessary paperwork, understand what your Mexican counterpart needs to support—and how your team can help keep the relationship moving forward.

Main Topic / Discussion
Supporting Mexican customs valuation starts with understanding the transaction—not just sending the invoice.

Miriam frames the discussion around traceability and materiality: documentation showing that a transaction occurred, how it was carried out, and why the declared value is supportable. That includes evidence of the commercial relationship, delivery, transportation, and payment responsibilities.

She describes requests for purchase agreements identifying the parties, tax identification, company addresses, the applicable Incoterm, delivery arrangements, and who pays for transportation. The conversation also explores how rebates, deductions, and year-end adjustments can complicate the connection between commercial pricing and Mexican import declarations.

The appropriate documentation depends on the arrangement. Miriam distinguishes sales transactions from pure maquila arrangements supported by a maquila services agreement. She also discusses related-party sales and the role of transfer-pricing analysis in supporting value.

Her closing recommendation is to cooperate with the importer on a master agreement that references existing purchase orders, commercial documents, and terms—rather than assuming the request requires starting every negotiation over.

Key Takeaways
• Do not dismiss the agreement request. Miriam urges U.S. exporters to take Mexican customers’ documentation requests seriously, even when the relationship has operated through purchase orders and invoices for years.

• Make the commercial details clear. The information Miriam identifies includes company names and addresses, tax identification, the applicable Incoterm, delivery terms, and responsibility for transportation costs.

• Pay attention to rebates and deductions. Miriam explains that these arrangements can complicate support for customs value. She also discusses the potential need to adjust Mexican import declarations, or pedimentos, when the value changes.

• Match the agreement to the relationship. Sales, pure maquila arrangements, and related-party transactions raise different documentation questions. Miriam discusses master agreements, maquila services agreements, and transfer-pricing support—not one document that automatically fits every situation.

Resources & Mentions
• Global Training Center

• Miriam Name — LinkedIn

• Cacheaux, Cavazos & Newton (CCN)

• IMMEX Blog Post

 

 

Follow Simply Trade for updates on companion resources and the 90 Days Until 2027 playbook.

This episode provides general educational information and is not legal advice. Confirm the documentation and valuation requirements applicable to your specific transaction.

Credits
Host:
Lalo Solorzano

Guest(s):
Miriam Name - LinkedIn

Producer:
Lalo Solorzano

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Host: Cindy Allen
Published: October 30, 2026
Length: ~ 14 min
Presented by: Global Training Center

Summary
Who stays to do the work after the party is over? In this episode of Simply Trade: Cindy’s Version, Cindy Allen uses Taylor Swift’s “New Year’s Day” to explore a question every importer should ask: what makes a customs broker a true partner when trade requirements change?

In her October 30 trade update, Cindy discusses Canadian Section 338 tariff litigation, CAPE refund developments, USTR activity, and enforcement concerns affecting the trade community. She then turns from the headlines to the people responsible for putting changes into practice—especially Northern Border customs brokers managing the tariff changes described in the episode.

The focus is not just on filing entries. It is on identifying affected clients, working through complex duty-treatment questions, coordinating entry and entry-summary timing, and communicating when decisions cannot wait. Cindy highlights the preparation and judgment behind that work, including the limits of automated tools when the details get complicated.

For importers, brokers, and compliance teams, this episode is a reminder to look beyond the visible transaction. The strongest partnerships are built on the quieter work that keeps both sides informed, prepared, and aligned long after the announcement lands.

This Week in Trade
• Section 338 litigation and CAPE refunds: Cindy reviews the challenge to Canadian tariffs, CAPE 3 developments involving protested entries, and the plaintiffs’ request for a CAPE 4 process covering antidumping and countervailing duty entries.

• USTR and Section 232 reviews: The roundup includes expected recommendations from the Section 301 overcapacity investigations, Airbus subsidy concerns, and the outcome Cindy reports from the robotics and industrial machinery review.

• Capitol Hill and Russian fuel imports: Cindy discusses political criticism of Canadian tariff adjustments and warnings to banks, ports, and fuel distributors about their involvement in Russian fuel imports.

• FMC enforcement: Cindy highlights increased scrutiny of ocean transportation intermediaries and the importance of having processes and procedures ready to address regulatory inquiries.

Main Topic / Discussion
Customs Broker Partnerships Beyond the Routine Entry
Cindy uses “New Year’s Day” as a metaphor for the work that happens outside the spotlight: preparation, coordination, and follow-through when tariff changes create difficult operational questions.

Her focus is on Northern Border customs brokers navigating the changes discussed in the episode. Identifying affected shipments is only the beginning. Brokers must also work through duty-treatment details, entry and entry-summary timing, and client communication—tasks Cindy explains cannot always be handled through automated tools alone.

The question for importers: who is prepared to work alongside you when the details become complicated, not just when everything is running smoothly?

Key Takeaways
• Look beyond the filing. A broker’s value includes the preparation, analysis, and communication that happen before an entry is submitted.

• Timing deserves close coordination. Cindy highlights how tariff transitions can raise questions about shipment timing, entry processing, and entry-summary filing.

• Reports do not replace judgment. Identifying affected transactions is different from resolving the complex duty-treatment questions behind them.

• Make the quiet work visible. Importers should recognize their brokers’ behind-the-scenes contributions, and brokers should communicate the work involved in supporting their clients.

Resources & Mentions
• Global Training Center
• Cindy Allen on LinkedIn
• Trade Force Multiplier — the global trade consultancy Cindy introduces in the episode.
• Taylor Swift’s “New Year’s Day,” from Reputation — the musical inspiration for this discussion.
• U.S. Court of International Trade — Cindy references filings involving Section 338 and CAPE refund developments.

Credits
Host:
Cindy Allen

Guest(s):
N/A

Producer:
Lalo Solorzano

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Host: Lalo Solorzano and Andy Shiles
Guest(s): Julie Ann Parks and Eugene Laney Jr., Ph.D.
Published: October 29, 2026
Length: ~38:40
Presented by: Global Training Center

Summary
Your trade team is getting more attention—but is it getting the resources, authority, and technology to match?

Lalo Solorzano and Andy Shiles welcome Julie Ann Parks of Altana and Eugene Laney Jr., Ph.D., of the American Association of Exporters and Importers (AAEI) to explore what it takes to move from constant firefighting to genuine trade readiness. Drawing on the joint Altana–AAEI report, The State of Enterprise Trade & Customs Organizations, the conversation examines the gap between growing expectations and the support available to meet them.

The discussion goes beyond keeping shipments moving. Where should trade compliance sit within an organization? What information should teams have before goods reach the border? And how can compliance leaders make a stronger business case for investment?

Julie and Eugene connect those questions to practical challenges: scattered product data, legacy systems, limited budgets, and uncertainty about AI. They also explain why automation should create room for human judgment—not replace it.

The episode closes with actionable “figure it out” advice for testing readiness, understanding the business impact of an enforcement response, and finding internal allies. For trade professionals preparing a resource request—and executives evaluating one—this conversation offers a starting point for turning compliance pressure into a more strategic role.

Main Topic / Discussion
The episode centers on using trade-readiness research to build a business case for change. The linked Altana–AAEI report surveyed 230 enterprise trade leaders: 51% of teams did not meet its trade-readiness threshold, while only 26% felt their resources had grown enough to keep pace. Altana

Julie and Eugene explore how reporting structures, budget authority, and access to product and supplier information influence a team’s ability to prepare before goods move. The conversation also tackles AI adoption, with an emphasis on automating mechanical work while retaining expert review. Their practical challenge: simulate a detention or CF-28 response, document the effort and business impact, and use that evidence to explain what needs to change.

Key Takeaways
• Move decisions ahead of the shipment. Julie emphasizes resolving product and compliance questions before goods are moving, rather than making last-minute intervention the default operating model.

• Make the business case in terms leadership understands. Connect resource requests to cycle times, sourcing decisions, tariff mitigation, and the costs of responding to enforcement—not just the compliance team’s workload.

• Give trade information a reliable home. The discussion highlights the need to bring product attributes, supplier relationships, and compliance information together rather than continually chasing answers across disconnected systems and spreadsheets.

• Pair technology with expertise and internal allies. Automate repeatable work, retain human validation, and involve IT in compliance education. Eugene also encourages identifying the people who can help communicate the program’s value to executive leadership.

Resources & Mentions
• Global Training Center
• Altana + AAEI Trade Readiness Report: The State of Enterprise Trade & Customs Organizations

Credits
Host:
Lalo Solorzano
Andy Shiles

Guest(s):
Julie Ann Parks — LinkedIn
Eugene Laney Jr., Ph.D. — LinkedIn

Producer:
Lalo Solorzano

📢 Subscribe & Follow
Stay connected with the Simply Trade community and never miss an episode that helps you trade smarter.

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💬 Connect with us:

• Simply Trade
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Don't forget to rate, review, and share with your fellow trade geeks!

Want to be on the show or have topic suggestions?
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