CBP Audits: What a Focused Assessment Looks Like

A CBP Focused Assessment is an audit of an importer's internal controls over customs compliance, run by CBP's Regulatory Audit staff. It tests whether the importer's processes for classification, valuation, origin and recordkeeping produce accurate entries, and it can lead to findings, unpaid duty and penalties. CBP also runs narrower Quick Response Audits on a single issue. The best preparation is knowing what your own entries say before CBP looks.

How a Focused Assessment runs

• Notice and entrance conference: CBP notifies the importer and explains the scope.
• Pre-assessment survey: CBP reviews the importer's import process and internal controls to decide where the risk is.
• Testing: If risk is found, CBP samples entries and tests them against the records.
• Findings and closing: CBP reports its findings, and the importer may need to pay lost duty and fix its process.

What CBP looks at

• Classification and how it is decided and reviewed.
• Valuation, including assists, royalties and related-party pricing.
• Country of origin and trade preference claims.
• Recordkeeping and how fast records can be produced.
• Special duties such as Section 301, 232 and antidumping.

How to prepare

• Run your own audit first. A post-entry audit shows errors before CBP finds them.
• Document your process: Written procedures for classification, valuation and broker oversight.
• Fix underpayments with counsel, possibly through a prior disclosure before the audit starts.
• Organize records so they can be produced quickly.

Frequently asked questions

Who gets audited? CBP selects importers based on risk, volume and other factors.

Is an audit only bad news? Preparing for one often turns up overpayments too, which can be recovered while windows are open.

How Caspian helps

Caspian audits every entry against the tariff schedule and your records, so you see what CBP would see. See our trade audit. This article is general information, not legal advice.

Works Cited:

• 19 CFR Part 163, Recordkeeping
• 19 U.S.C. 1509, Examination of books and witnesses