Are You Prepared for a Customs Audit?
Export Controls, Sanctions & Trade
October 19, 2022DownloadsDownload Service Sheet
As the U.S. government enters a new fiscal year as of October 1st, U.S. Customs and Border Protection (“Customs”) will begin its process of notifying importers of their selection for and required participation in various audit and assessment programs. While Customs audits cover routine compliance matters that may impact revenue collection, each year the agency focuses on various priority trade issues. Customs is expected to have a growing interest in country of origin declaration where special tariffs or trade remedies may apply and documenting supply chain due diligence for forced labor compliance.
Customs engages with the trade community through various types of reviews, including three levels of more formal audits and four non-audit assessments.
- Focused Assessment
- Referral Audit
- Customs Broker Audit
- Risk and Analysis Survey Assessment (RASA)
- Risk Assessment
- Customs Forms 28 or 29
- Import Specialist Inquiry
For more comprehensive reviews, such as a Focused Assessment, Customs may give advance notice but more targeted assessment activities can occur without warning. Customs typically initiates its review by sending the importer a questionnaire on the company’s trade activity and compliance procedures. Questionnaires may target specific topics such as valuation, country of origin, or supplier due diligence, giving the importer an indication of Customs’ perceived risks. Customs will often request review of sample import transaction and associated records, including entry summaries (Customs Form 7501), evidence of the right to make entry (airway bill or bill of lading), commercial invoices, packing lists, and bond information.