Control, Confidence, and Cash Flow:

How Walmart and GingerControl (GC) Transformed Duty Drawback into a Global Finance Strategy

At Walmart, every process is measured by scale. Every improvement, no matter how small, can ripple across continents. When you move millions of products a week, precision becomes the quiet backbone of progress.

That same precision drives the company’s approach to finance and compliance. Yet in one corner of its global logistics network, a hidden inefficiency was holding back millions in recoverable duties.

It wasn’t fraud, mismanagement, or neglect. It was fragmentation.

“Our suppliers managed drawback differently, and tracking refunds was chaotic,” says Cassandra H., Trade Finance Manager at Walmart. “We had the right people, but not the right system. Everyone was playing by a different set of rules.”

Duty drawback, the refund of import duties on goods that are later exported or destroyed should have been a predictable source of liquidity. For a company of Walmart’s size, it was a chance to bring the same discipline that defines its supply chain into its refund process.

That opportunity arrived with GC.

The Hidden Cost of Complexity

Walmart’s supply chain is a living organism: thousands of suppliers, multiple product categories, and constant movement through ports, warehouses, and export lanes. Every product carries its own customs classification and import record.

Under the Trade Facilitation and Trade Enforcement Act (TFTEA), importers can recover duties if they prove compliance under rules defined by U.S. Customs and Border Protection (CBP). That proof must show the link between import entries and export records, supported by valid entitlement documentation.

The challenge for Walmart was not eligibility. It was coordination.

Over time, different divisions had developed their own approaches to drawback. Some relied on third-party brokers. Others submitted claims internally through manual spreadsheets. The lack of a unified process meant inconsistent documentation, incomplete assignments, and limited visibility across claims.

“We had teams in Arkansas, Texas, and Pennsylvania, all filing perfectly valid claims, but in completely different ways,” Cassandra explains. “It was compliant, but it wasn’t cohesive.”

Refunds took months, sometimes quarters, to reconcile. And as new suppliers entered Walmart’s global ecosystem, the complexity only grew.

Bringing Order to a Global Operation

When GC joined the project, the mandate was clear: standardize the entire drawback process while protecting compliance integrity and accelerating refunds.

The partnership started with a comprehensive audit. GC's team mapped how data flowed between Walmart’s suppliers, brokers, and internal finance systems.

GC worked alongside Walmart’s finance and compliance leaders to build a single, unified framework: one policy, one process, and one technology platform that could scale across every product category.

Governance by Design

The cornerstone of the transformation was governance. Walmart’s new Duty Drawback Playbook established a standard for every participant in the process, suppliers, logistics partners, brokers, and internal teams.

The playbook defined:

• Standardized claim documentation requirements under TFTEA.

• Supplier obligations for providing proof-of-export and waiver assignments.

• Review protocols for Accelerated Payment and bond sufficiency monitoring.

• Escalation procedures for discrepancies or audit triggers.

“Before GingerControl, entitlement tracking was manual,” Cassandra says. “Now it’s automatic. Every assignment is digital, traceable, and stored with the claim.”

The Technology Layer: From Manual to Measurable

With governance in place, GC assisted with creating digital backbone for the new process. The platform connected directly to CBP’s Automated Commercial Environment (ACE), where all claims must be filed electronically.

Every claim now followed the same data structure. Import entries, export documentation, and entitlement certificates were pulled into a single workflow. Validation checks ran automatically before submission, flagging discrepancies in HTS codes, export proofs, or timing windows.

The system created what Walmart had been missing: visibility.

Executives could now see refund forecasts, claim statuses, and AP bond utilization in real time. This transparency turned drawback from a bureaucratic process into a financial dashboard.

“Our finance team went from waiting on updates to leading the process,” Cassandra says. “Now we know where every dollar is and when it’s coming back.”

The Finance Perspective: Turning Refunds into Strategy

Once Walmart’s drawback data became reliable, its finance team began to see new possibilities.

Refunds were no longer sporadic windfalls. They became predictable income streams that could be forecasted and budgeted. Treasury teams used refund timing to optimize short-term liquidity. Controllers integrated refund metrics into quarterly reports.

This shift changed how executives viewed drawback: from compliance maintenance to financial performance.

By linking drawback recoveries to key performance indicators (KPIs), Walmart began measuring efficiency not only in logistics but also in duty recovery.

“For a company our size, it’s not just about saving money,” Cassandra says. “It’s about knowing exactly where our money is tied up and how fast we can release it.”

Audit Readiness as a State of Normal

In the past, preparing for a CBP verification or audit meant weeks of pulling files, cross-checking documents, and waiting for brokers to respond. Under the new system, audit readiness became permanent.

Every claim in the platform carries its own digital audit pack, complete with import and export evidence, entitlement assignments, and submission logs.

If CBP requests verification under 19 CFR §190.61, Walmart can respond immediately, providing a clear, chronological record of each transaction.

“Audits used to interrupt us,” Cassandra says. “Now they’re just another task on the list. The data is always ready.”

The Results

Within the first year of implementation, the transformation delivered measurable impact:

• Claim acceptance rate rose to 99.9 percent.

• Refund timing improved by more than half, aligning with AP payout schedules.

• Supplier compliance reached 95 percent portal participation.

• Audit preparation time dropped from weeks to hours.

• Visibility and forecasting gave finance teams a clear view of duty recovery performance across regions.

The program also created a ripple effect throughout the organization. Suppliers became more engaged, logistics partners improved data quality, and finance teams used refund data to fine-tune their cash forecasts.

“It’s no longer a refund program,” Cassandra says. “It’s a visibility program that happens to recover money.”

Lessons in Control and Confidence

Walmart’s experience shows how large enterprises can turn regulatory complexity into operational advantage.

1. Centralization is the foundation of trust.
   A single system of record eliminates duplication and confusion. When data is consistent, compliance becomes predictable.

2. Governance must scale.
   A process is only as strong as the people who use it. Training suppliers, brokers, and internal teams to follow the same rules creates a sustainable ecosystem.

3. Visibility is value.
   Data transparency is not just about oversight. It empowers decision-making at every level from supplier management to treasury strategy.

4. Audit readiness is continuous.
   The most compliant organizations are the ones that treat verification as a normal business process, not a crisis event.

The Human Factor

For Cassandra, the real success lies not just in efficiency but in confidence.

“Our people don’t guess anymore,” she says. “They know. They trust the data, the process, and each other.”

That trust extends beyond internal teams. GC's structured communication with CBP’s Centers of Excellence built mutual confidence with regulators, leading to faster approvals and fewer inquiries.

Walmart’s drawback system now mirrors the discipline that defines its retail operations: structured, predictable, and scalable.

The GC Difference

GC’s philosophy is that compliance should not slow businesses down; it should make them faster. By combining deep regulatory expertise with data automation, the company builds systems that perform under pressure and scale with growth.

For Walmart, that philosophy translated into a duty-drawback process that runs quietly in the background, accurate, transparent, and fully aligned with its financial strategy.