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31 December 2025

Grandma Got Audited By A Reindeer

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Foley & Lardner

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So … it's Christmastime. Which can only mean it's time for the Christmas tradition that everyone has been waiting for all year!
United States International Law
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So ... it's Christmastime. Which can only mean it's time for the Christmas tradition that everyone has been waiting for all year! No, I'm not referring to your uncle drinking too much eggnog and falling asleep on the sofa and blocking everyone from watching sappy Hallmark Christmas specials, or even the annual debate about which person should get the re-re-re-gifted fruitcake. I'm talking about something MUCH bigger than that, which is our annual holiday compliance parody article!

But first, a few fun facts about the holiday song that regularly makes survey lists as BOTH the most- AND the least-liked holiday song:

  • "Grandma Got Run Over by a Reindeer" was rejected by every major record label, which meant that it was initially self-released, with a total pressing of 500 copies. As it gradually caught on as a holiday staple after being played on the Dr. Demento radio show, it was eventually picked up by a major record label. Its annual sales soon surpassed the previous perennial holiday sales record holder (Bing Crosby's "White Christmas") and has now sold over 11 million copies. It is not clear if "Grandma" was cut in for any of the royalties.
  • The song eventually inspired a TV special, which seems a bit odd in that the original song presents under three minutes of plot, half of which is a repeated chorus. Unlike in the song, Grandma actually survives in the cartoon.
  • The song inspired a Grey's Anatomy episode and also was featured on Family Guy, where three small monkeys pretend to sign the song at a funeral.
  • The song appears to be peculiarly American in its appeal. Although it was released in the United Kingdom, it did not even chart. But I imagine that if this alternative version had been released, it would have quickly shot to number 1:


Grandma Got Audited by a Reindeer

Grandma got audited by a reindeer,
Walking through the warehouse Christmas Eve.
Turns out Customs likes a precise invoice,
Not "miscellaneous goods" on a napkin in sharpie.


The value was listed as "best guess only,"
The HTS code field said "TBD."
The factory location was "Anywhere but Asia,"
Which CBP flagged immediately.


The reindeer opened up shipping records,
And her antlers perked up high with rage and fear.
The COO was listed as "Totally Not China,"
With a footnote that said "please, no penalties here."


Boxes labeled "Proudly Made in Canada,"
But with invoices written in Mandarin.
The reindeer said: 'This routing looks like transshipment,'
From farther east than any Canadian's ever been."


Chorus
Grandma got audited by a reindeer,
Right before the year-end close-out week.
Now the kitchen table's full of subpoenas,
And Grandma's drinking eggnog like it's tea.


Verse
The reindeer then ran through the sanctions lists,
And choked right on a ginger snap.
She said: "Grandma, why'd you call these gifts to Iran,
And say: 'OFAC has a license if you ship in gift wrap?'"


And, "why are all your invoices tied to blocked accounts?
With due diligence of 'Friends in distant lands?'
And wire instructions that say: 'please don't tell OFAC,
Sanctions screening is a far-off future plan."


Chorus
Grandma got audited by a reindeer,
With a checklist longer than a sleigh.
From mis-declared goods to global crime sprees,
She's on Santa's naughty list in every way.


Verse
Then the reindeer found the "special gifts,"
In envelopes under the tree.
"Paying Customs officials in foreign lands in small bills?"
Said Grandma, "That's just hospitality."


Gold-wrapped watches for port inspectors,
And a spa day for the port guy's wife and mistress too.
She said, "That's just international manners!"
The reindeer said, "Grandma ... I'm calling DOJ on you."


Chorus
Grandma got audited by a reindeer,
And the eggnog turned to regulatory tears.
Now Grandma's records are all on legal hold,
For the next ten Christmases of years.


Verse
Well, the reindeer took pity on the Grandma,
Cut a deal that fixed Grandma's compliance from head to toes.
Now Santa's workshop is Grandma's North Pole hotline,
And Elven auditors find suspicious gifts and naughty cash flows.


Chorus
Grandma got audited by a reindeer,
But now she's cleaner than the freshly fallen snow.
Even her pantry is now properly labeled,
With HTS codes on the peppermint and cocoa.


If you made it all the way to the end, you are probably the kind of person who would be interested in 'Twas the Night of Compliance, The Twelve Days of Compliance, and The Grinch Who Stole Compliance. If you would like to be added to our mailing list — which includes not only the occasional compliance parody article but also biweekly articles on What Every Multinational Should Know" about today's complicated international trade world — please click here.

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