CBP scrutinizes importer transactions for compliance with laws and regulations concerning classification, valuation, country of origin, tariff preferences, forced labor, antidumping and countervailing duties, and more. Taking a proactive approach can help make CBP reviews more efficient and remove much of the uncertainty of their outcome.

In an environment where laws and regulations are constantly changing and business operations must adjust accordingly, ST&R helps companies develop and document internal controls and customs compliance procedures they can use in day-to-day operations that reflect their unique operating environments. By analyzing multiple sources of available data, including ACE, we develop import compliance risk profiles for our clients and then conduct regular compliance reviews that test import-related internal controls and import transactions, identify potential deficiencies, and recommend any needed corrections or improvements. These reviews can also uncover opportunities for cost savings and increased efficiencies.

Why Use ST&R’s Import Compliance Review Services

Experience: ST&R’s dedicated audit group has more than 100 years of combined experience and includes former CBP Trade Regulatory Audit members who have held such positions as field director, policy director, assistant field director, computer audit specialist, senior auditor, and auditor. The group also includes a former member of the Canadian Border Services Agency with more than 30 years’ experience with import compliance verifications in Canada. ST&R attorneys have also conducted numerous audits of private-sector companies. Our experience and insight into CBP’s audit practices and methodologies enables us to conduct reviews in an effective and efficient manner.

Reasonable Care: Conducting compliance reviews is one way importers can exercise reasonable care, which can deter (or at least mitigate) possible penalty assessments and is a defense to retroactive duty assessments on liquidated entries. In addition, CBP has established that consulting with a customs expert like ST&R’s professionals is indicative of meeting the reasonable care standard. 

Duty savings: Internal investigations are a best practice for proactively identifying not only compliance issues but also potential opportunities to lower duty and other costs.



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