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Alliance International takes full responsibility for the drawback process from the initial implementation of the program to the filing of drawback claims. The first step in the drawback process requires that we conduct a thorough evaluation to quantify the recovery potential and assess the resources required to prepare claims and manage the program. The following summarizes the services that Alliance International performs throughout the drawback process:

Administrative Functions:

• Evaluate drawback potential for direct and "third party" drawback opportunities;
• Gather required drawback documentation and/or information from a client's forwarders and brokers. If possible, we prefer to gather the documents on-site to expedite the filing process;
• Perform drawback calculations and key required data elements into our specialized drawback system;
• Generate required Customs reports and forms, and file claims with Customs;
• Transmit portion of each claim electronically to Customs to expedite payment;
• Maintain documents to assist with record keeping requirements as outlined in 19 CFR 191.

Compliance Functions:

• Secure or update Customs privileges (accelerated payment and waiver of prior notice) with U.S. Customs;
• Draft and submit the required manufacturing drawback ruling if required;
• Conduct annual compliance assessments;
• Accurate preparation of the client's drawback entries;
• Draft any needed ruling requests and apply for participation in Customs new "Informed Compliance" Program when available;
• Provide on-site audit support in the event of a Customs audit

If the recovery potential justifies establishing a program, we will then conduct an on-site implementation
of a client's drawback program with the following objectives:

Develop Program Procedures - To ensure regulatory compliance, and to maintain the timely filing of drawback claims, we will develop comprehensive program procedures that address the following areas:

• Documents and data needed to prepare and file claims - To capture the needed documents, we typically employ a variety of methods including copying documents on-site, data downloads, and securing documents from a client's forwarders and brokers;
• Drawback record retention;
• General information related to the claimant's business practices and manufacturing processes;
• Frequency and objectives for periodic compliance reviews.

Review existing record retention - During the implementation visit we will review the types of records routinely required to substantiate claims during a Customs audit. While only a small portion of claimants will actually be audited, we prepare for the possibility of an audit from the inception of the program. As part of the implementation report, Alliance International will offer suggestions as to how to improve record retention procedures without creating an additional burden to the client.

Gather documents and information needed to prepare Customs applications - Alliance International will draft Customs applications for accelerated payment, waiver of prior notice, and draft a manufacturing ruling request if applicable. To prepare these applications, we will need to gather a variety of company information and sample documentation.

Understand client's business operations - As part of the implementation visit, we try to learn as much as possible regarding our client's specific business operations, and its industry in general. This knowledge assists us in designing a compliant drawback program, and can help us identify other potential drawback opportunities.