What CBP audits tend to examine
CBP's regulatory audits review whether entries were declared correctly and whether the importer's internal controls are designed to keep them that way. Some audits are broad assessments of an importer's compliance program, while others focus on a single issue such as a trade agreement claim or payments that may belong in customs value. The audit typically begins with a request for information and an entrance conference, moves through sampling and document review, and ends with findings that may identify unpaid duties. Importers must keep entry records for a set period and produce them on request, and failing to do so can bring penalties of its own. Audits can also be triggered by a pattern CBP has noticed across many importers in an industry, not only by anything specific to you.
Preparing for the entrance conference
Before the first meeting, know who in your company handles each part of the import process and how decisions on classification and value are made and checked. Assemble written procedures, broker instructions, the entry data CBP has requested, and any rulings you rely on. Decide in advance who will speak for the company, and keep answers accurate and limited to the questions asked. A single point of contact helps track what has been produced, so there are no gaps or contradictions later. Keep copies of everything provided, organized the way it was requested.
Findings, disclosures, and what follows
If the review reveals errors, whether a prior disclosure is still available, and how it would interact with the audit, depends on timing and on what CBP has already identified. Underpaid duties can usually be recovered, and penalties, when sought, depend on how careful the importer was. Audit reports may also recommend improvements that CBP will later expect to see in place. We review the audit letter and requests, look for issues likely to arise, and plan the response so the record reflects your actual compliance efforts.
