Prepare Your Company for a Customs Focused Assessment


U.S. Customs and Border Protection (CBP) is serious about the enforcement of import trade compliance. Here’s a primer on who’s likely to be audited, and what you should do before, during, and after a visit from CBP.

Who is most likely to face a Focused Assessment?

The top 5,000 entities in the United States that control 80% of imports, are one area of focus. But CBP also looks at as many other importers outside of those companies as their resources will allow. Other targets include companies with behavior patterns that are deemed to be potentially unlawful, those that have made even a single error in the past, and other importers at random.

In other words, just about any importer can be a target. Fines for trade-related transgressions depend on the seriousness of the infraction. They can range from fines up to $10,000 per entry for recordkeeping infractions to non-financial costs (e.g., shipment delays and diversion of your staff resources to correct problems) to other fees. In rare cases, you can lose your trade privileges.

12 steps to a smooth Focused Assessment

Before CBP arrives

  1. Create a flow chart for imports
  2. Assemble a response team
  3. Know the common pitfalls of importing
  4. Have a third party conduct a mock audit of your import process
  5. Correct compliance issues

While CBP is onsite

  1. Have relevant documentation on hand
  2. Make it mandatory for your response team to be present and available for the entire audit
  3. Be cooperative and provide the information that is requested
  4. Hold CBP accountable to their promised timeline for response to avoid business disruption

After the focused assessment

  1. Join an industry and/or government program like the CTPAT Trade Compliance Program
  2. Review your compliance training program and schedule periodic mock audits
  3. Build broad support for compliance in your organization

Dig deeper into this priority topic

There are many resources you can consult to learn more about Focused Assessments. Start by reviewing our white paper on how to prepare for a Focused Assessment and then visit the CBP website.

You can also contact local and national trade associations that may have training materials and case studies you can reference. Finally, don’t try to do it all alone. Connect with our trade policy experts. Our in-depth customs expertise can help you stay compliant.