How to Get the Most from AI Drawback
Ryan Janusee
4
Nov 18, 2025
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Adopting an AI-powered duty drawback platform is a strategic decision that can unlock significant cash flow and enhance compliance. However, successful implementation requires a shift in mindset—from treating drawback as a manual accounting task to managing it as a sophisticated, data-driven financial process. The greatest implementation error is not technological, but procedural: treating the system as a "set it and forget it" solution. The key to success is combining the power of AI with expert human oversight to create a robust, optimized process.
Embrace the "Human-in-the-Loop" Model
Advanced AI models are probabilistic, meaning they find likely matches rather than just exact ones. This capability is a feature, not a flaw, as it uncovers opportunities manual reviews might miss. However, the best practice is a "human-in-the-loop" approach. In this model, the AI suggests and optimizes claims, while a human expert provides the final review and approval. This retains full human control and legal accountability while capturing the speed and optimization benefits of the platform.
Prioritize Data Governance and Security
Because AI drawback systems centralize sensitive commercial data, data governance must be a critical component of implementation. Just as with any ERP or financial system, it is essential to use a reputable provider with robust protections against cyber threats. This is a standard part of modern IT governance rather than a new risk unique to AI, but it requires diligence to ensure your proprietary data remains secure.
Demand Auditability and Transparency
A well-designed AI platform should be more auditable than any manual process. When choosing a provider, you must select a platform that provides a clear, auditable trail for every match it makes, explicitly explaining why it linked a specific import to an export. This transparency is crucial not only for internal validation but also for surviving external CBP reviews with confidence.
Understand Legal Liability
It is vital to remember that the claimant, not the software, retains the legal liability for a claim's accuracy. This reinforces the necessity of the human-in-the-loop model. AI is a powerful tool designed to assist a human expert; it is not a legal entity to which you can abdicate responsibility. Ensuring your team understands this distinction is key to maintaining a compliant drawback program.
Navigate the Regulatory Landscape (CBP & Global)
Currently, CBP is tool-neutral, focusing on the evidence required for a claim (per 19 C.F.R. §190) rather than the technology used to find it. However, as AI becomes standard, CBP will inevitably develop AI-specific audit protocols, rewarding systems that are auditable and transparent. Furthermore, companies must navigate a fragmenting world of AI rules—from the EU's structured framework to the U.S.'s decentralized approach—making an adaptable AI compliance strategy essential.
Elevate the Role of the Drawback Professional
One of the greatest benefits of AI is that it unburdens customs professionals from low-value data entry, elevating their role from clerk to strategic advisor. The job shifts from managing spreadsheets to higher-level decision-making, such as validating AI recommendations and analyzing the program's financial impact. This creates a more valuable professional who understands regulations, financial impact, and data science.
