Architects of the Industry
In the work of duty drawback, there is a profound difference between a practitioner and an architect. While most firms interpret the regulations to find refunds, Comstock & Holt has spent decades defining what those regulations are.
As the oldest duty drawback specialist organization in the United States, our footprint is woven into the fabric of modern trade legislation. We don’t just track industry trends-we set them. By serving as a bridge between industry needs and legislative action, we ensure our clients aren’t just following the law; they are benefiting from the most sophisticated interpretation of it.
Legislative Authorship
We were instrumental in the authorship of the Customs Modernization Act of 1993, including the introduction of the pivotal “unused merchandise” concept. Our influence continued through the negotiation of the Trade Facilitation and Trade Enforcement Act (TFTEA) of 2015.
Regulatory Precision
We believe in precision over guesswork. Our proactive review of 19 C.F.R §190 led to critical revisions regarding manufacturing drawback values and proof of export, ensuring the regulatory landscape is fair and functional for our clients.
Direct Government Advocacy
Comstock is a recognized voice in Washington and across the drawback community. Through leadership roles in multiple duty drawback industry groups, we maintain direct connections throughout government and remain actively engaged in the conversations that shape the future of drawback.
The Future of Recovery: Proprietary Drawback Software and AI
Legacy is our foundation, but innovation is our trajectory.
We believe that the deepest institutional knowledge in the world should be paired with the fastest technology available. To achieve this, Comstock is currently developing a proprietary, in-house AI platform.
This isn’t just another software tool. We are translating decades of legislative, regulatory, and operational expertise into a digital knowledge system that can help identify recovery opportunities more consistently and efficiently. By capturing institutional knowledge in a structure form, we can improve the speed and quality of refund-recovery analysis while reducing the risk that opportunities are overlooked. This AI will partner with our own proprietary drawback recovery software, and always have oversight by our experienced specialists.
The Human Guardrail
Technology accelerated the process; experts ensure the result.
While our AI drives efficiency, we believe that high-stakes customs business requires human judgment. Comstock remains the only U.S. drawback specialist with 15 licensed Customs Brokers.
The powerhouse team serves as the essential guardrail for every claim. Our brokers provide the nuance, the ethical oversight, and the professional authority required to navigate the intricacies of U.S. Customs. When you partner with Comstock, you get the perfect synergy: The precision of proprietary drawback software and AI backed by the authority of the nation’s leading licensed experts.