Affiliate recruitment · 3-tier commission

Get paid to connect importers to $166 billion in owed refunds.

The Supreme Court struck down IEEPA tariffs. Thompson Coburn is filing refund claims. Opscale Exchange runs the affiliate program. You bring the lead — we handle everything else.

Target pool
~50,000
Qualified businesses
Commission pool
6%
Of every gross refund
Out of pocket
$0
Zero cost to affiliates
The window is finite
$166B

is what the federal government collected in IEEPA tariffs the Supreme Court ruled illegal. Every business that paid these tariffs between February 2025 and February 2026 is entitled to a refund. Only a fraction know it. Fewer still know how to claim it before deadlines run out.

Why this program is different
01

The legal angle is real

This isn't affiliate marketing for a product. SCOTUS issued the ruling. CBP is building the refund system. Thompson Coburn is filing cases at the Court of International Trade. The money is legitimately owed.

02

You don't close the deal

Affiliates make the introduction. Thompson Coburn handles eligibility review, legal strategy, and client conversion. You don't need to understand IEEPA law or sell a legal service.

03

Recurring tier structure

Bring in sub-affiliates and earn on their deals too. A sub-rep you recruit who closes a deal pays you 10% of the commission pool — on top of whatever you close directly.

Commission structure

Three tiers. 6% of every gross refund.

Every refund that closes generates a commission pool equal to 6% of the gross payout (20% contingency × 30% pool allocation). That pool splits three ways across the referral chain.

Tier 1
Referral rep (closer)
70%
of commission pool
On a $350K refund
$14,700
Tier 2
Sub rep (you recruited them)
20%
of commission pool
On a $350K refund
$4,200
Tier 3
Original referrer (your recruiter)
10%
of commission pool
On a $350K refund
$2,100

How the math works · Simple pass-through from gross to pocket

Gross refund
$1,000,000
20% contingency
$200,000
30% pool
$60,000
$60,000 commission pool → $42,000 tier 1 · $12,000 tier 2 · $6,000 tier 3
What you actually earn at different deal sizes
Gross refund
Tier 1 (closer)
Tier 2 (sub-rep)
Tier 3 (recruiter)
$100,000
$4,200
$1,200
$600
$250,000
$10,500
$3,000
$1,500
$500,000
$21,000
$6,000
$3,000
$1,000,000
$42,000
$12,000
$6,000
$2,500,000
$105,000
$30,000
$15,000
$5,000,000
$210,000
$60,000
$30,000

Commissions paid only on successfully recovered refunds. No upfront cost to affiliates.

How it works as an affiliate
01

Apply & activate

Complete the affiliate agreement. You receive a unique referral link and access to the full outreach library.

02

Share with importers

Use the provided scripts, emails, and social content. Route qualified leads to your personalized intake page.

03

Thompson Coburn takes over

Once a lead submits intake, Thompson Coburn handles review, engagement, litigation, and recovery. You step aside.

04

Get paid on recovery

Commission paid within 30 days of refund receipt. Direct deposit to your chosen account.

Who this program is for

Great fit

  • Accountants, bookkeepers, and fractional CFOs with importer clients
  • Customs brokers and logistics professionals with deep industry relationships
  • Trade consultants, supply chain advisors, and industry association members
  • B2B sales professionals with established mid-market networks
  • Business owners who know other business owners that import
  • Agency owners and growth marketers with manufacturing or retail clients

Not a fit

  • Anyone hoping for "passive income" with no outreach activity
  • MLM recruiters focused on recruitment volume without real industry connections
  • Affiliates unwilling to follow compliant messaging guidelines
  • Anyone attempting to solicit with unverified claims about refund amounts
  • Cold spammers who will burn domains and damage the program's reputation
Tools we provide

Full outreach library

Vetted phone scripts, email sequences, and social posts. Compliant with Thompson Coburn advertising guidelines.

Commission calculator

Interactive calculator to show prospects their refund estimate. Branded with your referral link.

Dedicated support

Affiliate Slack, monthly strategy calls, and a dedicated rep who answers within one business day.

Real-time tracking

Dashboard showing leads submitted, engagement status, and projected payouts across all tiers of your downline.

Branded landing pages

Personalized intake pages at your own sub-URL. Prospects see your name, your introduction, your call scheduler.

Training & certification

On-demand training modules covering IEEPA basics, objection handling, and compliant positioning.

Common questions
Do I need to know trade law or tariff details?
No. You're introducing potential clients to Thompson Coburn, not providing legal advice. You provide high-level awareness ("you may be owed a refund on 2025 tariffs"), and the attorneys handle everything from eligibility review forward. Your training covers what you need to say and, more importantly, what you should never say.
When do I actually get paid?
Commissions are paid within 30 days of Thompson Coburn receiving a recovered refund on a qualified deal you referred. Some claims resolve quickly through CBP's CAPE system; others require CIT litigation and take longer. You're paid when money is delivered, not when the case is filed.
What's the recruiting tier structure?
When you recruit a sub-affiliate, they become Tier 1 on deals they close directly. You become their Tier 3 (earning 10% of the commission pool on their deals) because they also bring an original referrer above them. If your sub-rep recruits someone else, that third affiliate's deals generate Tier 2 income for your sub-rep and Tier 3 for the original recruiter. The structure is strictly three tiers deep — no downline sprawl.
Are there caps or claw-backs?
No cap on total earnings. Claw-back applies only in cases of refund reversal by CBP (rare but possible), fraud by the client, or affiliate misconduct. Legitimate commissions on recovered refunds are yours permanently.
Can I use paid ads or cold email?
Cold email and outbound outreach are permitted using the provided compliant templates and sending infrastructure guidelines. Paid ads require pre-approval on creative and landing page content to ensure compliance with state bar advertising rules (Thompson Coburn's requirement, not ours). Spam, misleading claims, and unapproved ad creative result in affiliate termination.
Can I represent myself as a legal service?
No. Under no circumstances may affiliates imply they provide legal services, represent clients, guarantee specific refund outcomes, or speak on behalf of Thompson Coburn. You are an independent referral affiliate. The provided training and scripts keep you safely inside proper positioning. Violations result in immediate termination.
What does the intake process look like for a referred client?
Your lead clicks your referral link and lands on a personalized intake form. They submit their company details and import information. Thompson Coburn reviews the records and confirms eligibility within 5-10 business days. If qualified, the client receives an engagement letter and the $10,000 flat fee is collected. Litigation is filed; recovery follows. You receive status updates throughout.
Is there an application or approval process?
Yes. Apply using the form below. We review within 3 business days. Approval is based on industry relationships, professional background, and willingness to complete the 45-minute training module. We accept approximately 70% of qualified applicants and reject those we believe will damage the program's compliance posture.
Limited onboarding cohorts

Ready to earn on real recoveries?

Apply now. If accepted, you'll complete onboarding, receive your referral link and materials, and be making active introductions within a week.

Affiliate participation subject to approval and execution of a separate Affiliate Agreement. Commissions are paid on successfully recovered refunds only, per the commission schedule published in the Affiliate Agreement. Affiliates are independent contractors and do not provide legal advice or services. All legal representation is provided by Thompson Coburn LLP under a separate engagement agreement with the client. Past program performance does not guarantee future results. Refund amounts depend on individual client import history and regulatory developments. Affiliates are responsible for their own taxes. © 2026 Opscale Exchange LLC.