Strategies and suggestions for verification: Organize the verification materials in advance

08/12/2022 04:38 - 92 Views

Given the amount of detail that the Commerce Department expects, a week is a short time within which to finish a verification. A foreign company must therefore organize its materials to help the verification go as smoothly and efficiently as possible.

 

Wasting time during the verification trying to locate the necessary documents increases the risk that the Commerce Department will find that the foreign company has failed verification.

 

Our experience has been that the best way to organize materials for a verification is to copy all of the relevant documents in advance, and place all the documents relating to a particular topic into a labelled folder. Where a particular topic involves several transactions, each transaction should have a separate folder. This method of organizing materials has two advantages. First, it organizes all of the documents in an easily understood and flexible system. If the order of the verification changes, the documents can be presented in the new order very easily. Since the Commerce Department staff will take back to Washington D.C. large numbers of documents as verification exhibits, such a system also makes it much easier for the Commerce Department staff person to collect the necessary exhibits for the verification report.

 

Second, and more important, preparing the documents in advance forces the company staff and the lawyers to review carefully every document to be used during the verification. It is crucial to review all of the documents before the verification. Any problems should be discovered so that they can be solved. Every company has minor discrepancies in its accounting system. As long as the discrepancies are explained persuasively, they generally do not create a problem at the verification. Unexplained discrepancies, however, can be a disaster. It often takes some time to resolve discrepancies, so the sooner they are discovered, the easier it will be to deal with them in a satisfactory manner.

 

Source: Business Guide to Trade Remedies in the United States: Anti-dumping, countervailing and safeguards legislation practices and procedures

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