Prior Disclosures

A properly filed prior disclosure of a potential customs violation, which may be surfaced through a self-assessment or CBP inquiry, can be an effective mechanism to limit associated penalties. Our legal and audit teams combine to provide expeditious and comprehensive analysis of import data to ensure not only that such disclosures pass customs scrutiny but also that companies achieve the most favorable outcome. 

Legal experience: Our staff includes attorneys who served in senior positions in CBP’s penalties branch, adjudicating prior disclosures and training Fines, Penalties, and Forfeitures officers throughout the country in administering such matters. In addition, our team includes former Department of Justice attorneys who have litigated enforcement cases that often involve prior disclosure issues. 

Audit experience: STR’s dedicated audit group includes former senior CBP audit directors and managers. These experienced professionals analyze systems to determine causes of errors, perform statistical sampling, quantify revenue discrepancies, recommend corrective actions, and craft successful disclosures for submission to CBP. 

Discernment: We’ve helped a wide range of companies evaluate the pros and cons of filing prior disclosures and can effectively determine whether and how the process can work for you.