Mock Customs Audits

The purpose is to enhance an importer's ability to exercise "reasonable care".

From CBP’s Informed Compliance Strategy, this is what CBP expects of the Trade …

The Customs Modernization Act is based on two basic tenets, shared responsibility and informed compliance. Shared responsibility means that importers and Customs have a mutual responsibility to ensure compliance with trade and Customs laws. At a minimum, Customs believes this will require the trade to obtain and apply to its import transactions the information Customs makes available through its Basic Information Program. In addition, the trade will be expected to:

 

·          Apply information that Customs makes available under its "Targeted Information Program" to address specific industry and trade segment issues;

·         Establish internal controls over its Customs operations;

·         Ensure personnel involved in Customs activities are properly trained;

·         Work in partnership with Customs to develop informed compliance programs; and

·         Seek clarification when Customs requirements are not understood.


Gathering of information prior to opening of process – questionnaire asked by mock auditor to persons responsible...

Follow similar process as Customs Assessment Team (CAT) Compliance Outline – using the “CAT Kit”

Proactive approach to Risk Management

Use the Importer Self Assessment questionnaire, Reasonable Care Checklist, and Recordkeeping Requirements as guidance for areas to focus 


Random import file & clearance process review

Using a checklist, focus on import documents (PO, commercial invoice, CF 7501, transportation invoice, packing list, documentation flow timeline) for

·         Classification accuracy

·         Statistical information accuracy

·         Valuation correctness compared to actual PO and transaction

·         Trade Act certification and compliance

·         Country of origin marking

·         ADD/CVD

·         Broker performance level – incidence of timely delivery, follow-up

·         Interface with other government agencies, if applicable

·         Refund, Protest numbers, procedures, and success levels

International Operations Manual on Disk 

  • Office Policies of a Customs Broker office

  • "How to" not found in the Customs Regulations

  • Operations Procedures of a Customs Broker office

  • Import - Export References

  • Customs Compliance Review materials

  • Customs Clearance Tutoring (course format and links)

  • Operation Formats used in a Customs Broker office

  • Professional International Freight Forwarder handouts

  • Export Documentation -- the story behind the documents


Cost, including the International Operations Manual on Disk:
$85.00 / hour per company... $42.50 / hour for "incentive" pricing (minimum 16 hours / month)


About the instructor, David Bennett ...

Licensed by U.S. Customs in 1980

Former President & Director Baltimore Customs Brokers & Forwarders
Association

Owner, Branch manager, import manager, & import clerk for Customs
Brokerage firms

Instructor of "Customs Brokerage License Preparation" course

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Training ... Six Courses for International Trade

Trade Library  ... Support for Import/Export Operations

Logistics ... Eliminate the Middleman

Trade Manager ... Importer / Exporter of Record Management

Copyright © 2000 H.C. Bennett Company. All rights reserved.
Revised: October 07, 2010