19 CFR Part 146 Every filing, every reconciliation — verified against the regulation

The most rigorous FTZ compliance engine a mid-market operator can run.

ZoneKeeper is a done-for-you managed service that owns the customs back office of your U.S. Foreign-Trade Zone: every e214 admission, weekly consumption entry, inventory reconciliation, and annual reconciliation report filed correctly and on time — maximizing duty deferral, inverted-tariff and MPF savings while eliminating operator-bond liquidated-damages exposure. AI is the internal engine; a licensed customs broker is the signing chokepoint.

Every subsection of 19 CFR Part 146e214 · weekly entry · annual reconciliationDHSMV · USCG · UCC · judgment lien searchesLicensed customs broker sign-off on every entry5-business-day SLA
Why compliance fails

A single unreconciled balance can trigger bond liquidated damages up to 3× the merchandise value.

A Foreign-Trade Zone saves real money — duty deferral, inverted-tariff relief, MPF consolidation — but only if the paperwork is perfect. Every unit admitted on an e214, every withdrawal entered, every balance reconciled, and an annual reconciliation certified to CBP. Miss one step, and the operator bond is exposed to liquidated damages up to three times the value of the merchandise.

Most mid-market operators run this on thin trade-compliance teams and spreadsheets. The tariff landscape just spiked — Section 232 steel/aluminum at 50%, Section 301 up to 100% on select China goods — and the volume of FTZ activity is straining manual processes.

ZoneKeeper exists to close that gap with a single, exhaustive standard applied identically to every file.

$1.42M
annual MPF saved in one published footwear example via weekly-entry consolidation — the upside we protect and capture
The benchmark

Measured against the letter of 19 CFR Part 146 — subsection by subsection.

We do not summarize the regulation and hope. Every pack is scored against a versioned rule pack tied to the exact text of 19 CFR Part 146. These are the provisions each pack is held to.

19 CFR 146.11

e214 admissions

Every admission of foreign merchandise into the zone is filed on CBP Form 214, with correct zone status election (privileged foreign, non-privileged foreign, domestic) and HTS classification.

19 CFR 146.22

Weekly consumption entries

Withdrawals for consumption are entered weekly, consolidating MPF and duty, with accurate valuation and HTS under the inverted tariff where applicable.

19 CFR 146.43

Inventory reconciliation

Running reconciliation of receipts, withdrawals, transfers, and on-hand balances, with zero unexplained variance at any point.

19 CFR 146.44

Annual reconciliation report

Mandatory annual reconciliation certified to CBP by the operator, covering all zone activity and inventory for the prior calendar year.

19 CFR 146.53

Operator bond & liquidated damages

The operator bond is maintained and all filings are timed to avoid defaults that trigger liquidated damages up to three times the merchandise value.

19 CFR 146.71

Recordkeeping & audit readiness

All admission, entry, reconciliation, and supporting documents are retained and organized for CBP audit, with a complete evidence log.

How a pack is built

Intake to broker release, with deterministic gates the AI cannot overrule.

AI extracts and drafts. Deterministic rules — running as code, outside the model — decide what is complete. A licensed customs broker validates at judgment chokepoints. That order is never reversed.

01

Compliance Gap Scan

Upload your FTZ activity data (admissions, withdrawals, inventory). We return a free completeness read: which filings and reconciliations are current, and which are missing or at risk.

02

Evidence & data ingestion

As your authorized clerical agent, we ingest invoices, packing lists, BOLs, ERP inventory movements, and prior filings to build a complete transaction record.

03

Grounded drafting

e214 admissions, weekly entries, and reconciliation reports are drafted from validated data and the 19 CFR Part 146 rule pack into field-locked templates — no legal opinions, no invented facts.

04

Deterministic completeness gates

HTS classification is verified against the HTSUS; zone status election is checked; duty and MPF calculations reconcile to the penny; inventory balances tie out; any failure blocks release.

05

Broker review & sign-off

A licensed customs broker reviews the exception queue and signs each entry. High-value or complex classifications route to senior broker review.

06

Delivery

You receive the complete filing package: e214s, weekly entries, reconciliation reports, evidence log, and a compliance calendar — ready for your authorized officer to certify and submit.

The bar we hold

Rigor you can measure.

100%
Broker-signed entries
No entry ships without a licensed customs broker signature.
5 days
Standard SLA
From complete intake to released filing package.
<1%
Critical-defect target
Tracked against a gold-standard filing library.
4
Data sources reconciled
Invoices · BOLs · ERP · prior filings, every applicable file.
Why ZoneKeeper

Built to be the most thorough option a mid-market operator has.

Documentation-complete, by design

The deliverable is completeness itself — every filing and reconciliation accounted for or explicitly exception-coded. Nothing is left implicit.

Deterministic, not vibes

The gates that decide completeness are code, not a model's opinion. A drafting error cannot slip past a regulatory requirement.

In its lane, on purpose

We prepare documentation and run searches as your clerical agent. We never give legal advice, classify HTS as a broker, or certify the reconciliation — that remains your authorized officer's duty.

Engagement

Flat retainer + per-filing fee. No contingency, ever.

Simple, predictable, and aligned with a compliance standard — not a cut of any duty savings.

  • A free Compliance Gap Scan before you commit — see exactly what is missing or at risk.
  • One flat monthly retainer per FTZ site, plus disclosed per-filing fees for e214s, weekly entries, and the annual reconciliation.
  • Optional fixed-fee senior broker review for high-value or complex classifications.
  • Optional Audit-Ready Add-on for full recordkeeping and CBP audit preparation.
FAQ

Questions, answered precisely.

Is ZoneKeeper a law firm or customs broker?
No. ZoneKeeper, a service of Your Deputy, Obuke LLC, provides documentation-completeness and clerical services. It is not a law firm, does not provide legal advice, and is not a licensed customs broker. All entries are signed by a licensed customs broker through our partner network.
Do you contact CBP or file entries on my behalf?
We prepare the documentation and run the data reconciliation. The filing is submitted through a licensed customs broker who signs the entry. Your authorized officer certifies the annual reconciliation. We never represent you before CBP.
What makes a filing 'complete'?
Completeness is defined by 19 CFR Part 146: every e214 admission, weekly entry, inventory reconciliation, and annual reconciliation report present, with correct HTS, zone status, valuation, and duty/MPF calculations. Deterministic gates enforce each one before release.
How fast is it?
The standard SLA is five business days from complete intake to a broker-released filing package. The free Compliance Gap Scan is returned much sooner and tells you exactly what is still needed.
How are you priced?
A flat monthly retainer per FTZ site, plus disclosed per-filing fees. No contingency and no percentage of any duty savings or recovered amounts.

See what's missing before it costs you a bond default.

Start with a free Compliance Gap Scan. Send your FTZ activity data and we'll return a completeness read against every subsection of 19 CFR Part 146.

Documentation-completeness service · not legal advice · your authorized officer certifies every filing.