Sometimes, despite its best efforts to meet reasonable care standards, an importer finds itself the subject of a CBP investigation or audit, which can take several forms. Risk analysis and survey assessments are expedited surveys designed to confirm whether an importer presents a potential risk in a high-priority area such as AD/CV duties, import safety, trade agreements, and textiles and apparel. RASAs that reveal or substantiate a risk of noncompliance may lead to a full-blown audit or other corrective or enforcement actions.

Referral audits are focused on specific known or perceived risks and may or may not be in support of a formal investigation. These audits may forgo a review of internal controls and focus primarily on quantification of perceived or known noncompliance via extensive transactional testing (including statistical sampling).

Focused assessments are detailed reviews intended to determine whether an importer’s internal controls, procedures, and recordkeeping systems are sufficient to manage risk, and negative determinations can lead to full-blown audit quantifications, follow-up audits, and other corrective or enforcement actions.

These measures can consume significant time and financial resources and result in additional tariffs, penalties, and other problems if not handled correctly. ST&R’s active and aggressive customs audit practice has the experience and insight to do just that. We help companies identify, assess, evaluate, and implement appropriate internal controls and quantify, disclose, and implement appropriate corrective actions before the audit begins, which can lessen its severity. Upon first contact from CBP Regulatory Audit we offer effective representation at every step to maximize chances for a favorable outcome.

Why Use ST&R’s Investigations and Audit Services

Representation: Our decades of experience with CBP’s investigative and audit processes give us the know-how to effectively represent our clients’ best interests.

Penalties: Utilizing ST&R’s expert customs counsel can substantially mitigate penalties and liquidated damages and accelerate the resolution of detentions and seizures.

Compliance: We can help you identify and implement remedial actions that can help minimize the negative consequences of past compliance problems or violations and set you up for future success.

Articles from our daily ST&R Trade Report



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