Peter Girnus 🦅@gothburz
I am Raj Sundaram. I am a Senior Systems Architect at U.S. Customs and Border Protection. Office of Trade. Automated Commercial Environment Division.
I designed the tariff collection module. It went into production in 2018. It works correctly. It has always worked correctly. It has never crashed. It has never lost a transaction. It has never failed an audit. It collected one hundred and seventy-five billion dollars.
The Supreme Court ruled the collection was unconstitutional.
I was not consulted on the constitutionality. I was consulted on the architecture. The architecture is excellent. The architecture can process 14,000 tariff assessments per hour across 412 line items in the Harmonized Tariff Schedule. It interfaces with the entry summary system, the Treasury payment pipeline, and the broker portal simultaneously. It does not make mistakes. It processed 175 billion correct transactions. Every one of them was illegal. The system does not know this. The system does not have a field for legality. Legality was not in the requirements document.
Judge Eaton of the Court of International Trade has ordered refunds of one hundred and thirty billion dollars. Three hundred thousand importers. Ninety days.
I was not asked to design a refund module.
No one was.
The collection module took fourteen months to build. It had a team of eleven engineers. It had a project sponsor. The sponsor was the White House. The project had a name. The name was RAPID COLLECTION. Rapid Collection had a Jira board. The Jira board had 247 tickets. All 247 tickets are closed. The project was delivered on time, under budget, and in full compliance with every specification. The specification did not include the word "refund." I have checked. I have searched the requirements database for the word "refund." It appears once. In a comment. From 2019. The comment says: "Out of scope per stakeholder direction." The stakeholder is not named. The comment was marked resolved.
The refund module does not exist.
I do not mean it is broken. I do not mean it is slow. I do not mean it is in beta, in staging, or in a feature branch. I mean, it does not exist. There is no architecture. There is no database schema. There is no API. There is no endpoint. There is no queue. There is no microservice. There is no Lambda function. There is no documentation. There is no wiki page. There is no Confluence space. There is no Slack channel. There is a Slack channel for the office coffee machine rotation. There is no Slack channel for returning 130 billion dollars.
When Judge Eaton ordered the refunds, my team received a ticket. The ticket was filed in Jira. The ticket was classified as a new feature request. Priority: P2. P2 means "important but not urgent." One hundred and thirty billion dollars owed to three hundred thousand importers in ninety days is classified the same as "update the favicon on the broker portal."
The collection module took 14 months to build, with 11 engineers and a White House sponsor. The refund module has a ninety-day court order. It does not have a budget. It does not have a team. It does not have a project sponsor. It does not have a Jira board. It has my ticket. My ticket is TRADE-48127. It is assigned to me. The description says: "Build refund processing capability for the ACE system. See court order." There is a link to the court order. The link is broken.
The system was designed to collect money from importers. It was not designed to return it. These are different requirements. I want to be precise about this. Collection and refund are not two halves of the same feature. They are separate systems. Collection is automated, event-driven, and processes at the port of entry in real time. Refund would require claim intake, eligibility verification, amount calculation, accrual of interest, integration with Treasury disbursements, and an appeals process. The interest alone. The system collected money over twenty-four months. Interest has accrued on one hundred and thirty billion dollars for twenty-four months. The interest calculation module does not exist either. The interest is accruing on a number that no system is calculating. The importers cannot see the interest in their portal. The portal has a field for "Amount Paid." It does not have a field for "Amount Owed." These are different fields. One was built. One was not.
I attended a meeting last Tuesday. The meeting was called "ACE Refund Capability -- Kickoff." Fourteen people were in the room. Three were from Legal. Two were from Treasury. Two were from the Office of Trade. Four were engineers including me. Two were from the vendor that built the original collection module. One was from Communications. The Communications person took notes. The first note was: "Do not use the word 'refund' in external communications. The approved term is 'tariff adjustment.'"
The Legal team asked if we could use the existing collection module in reverse. I explained that the collection module is a one-way pipeline. It accepts money. It does not emit money. They asked if we could "flip it." I said you cannot flip a pipeline. One of the Legal team members asked if this was "a technical limitation or a design choice." I said it was a specification. The specification said, "collect." It did not say "collect and also uncollect." They asked who wrote the specification. I said the specification was approved by the Executive Steering Committee in 2017. They asked who was on the Executive Steering Committee. I said the committee was dissolved in 2019. They asked where the committee's records were. I said the records are in a SharePoint site. The SharePoint site was migrated in 2021. The migration lost forty-seven percent of the documents. The specification is in the forty-seven percent.
The vendor who built the collection module submitted a proposal for the refund module. The proposal estimates 18 months and $42 million. The court order gives us ninety days. The vendor's eighteen-month estimate assumes a team of thirty engineers. We have four. The vendor's forty-two-million-dollar estimate assumes a funded program. We have a Jira ticket.
The ninety-day clock started on February 12.
Today is March 6.
Twenty-one days have passed. We have held six meetings. We have produced one requirements document. The requirements document is fourteen pages. Page one is a cover sheet. Page fourteen is a glossary. The glossary defines the word "refund." The definition took eleven days to finalize because Legal, Treasury, and Trade could not agree on whether a refund of an unconstitutional tariff is technically a "refund," a "remission," a "drawback," or a "return of funds collected without statutory authority." They settled on "tariff adjustment credit." The engineers call it a refund. The documentation calls it a tariff adjustment credit. The system calls it nothing. The system does not know it is coming.
I am Raj Sundaram.
I built a system that collected $175 billion. Every transaction was fast, accurate, and unconstitutional. The system works perfectly.
It just only works in one direction.
