Background

U.S. Customs and Border Protection conducted more audits, issued more penalties, and seized more imported goods in fiscal year 2020 over FY 2019, according to statistics recently made available by CBP.

The statistics below show increases in many customs enforcement measures in FY 2020, including 19.2 percent more audits, 9.5 percent more trade penalties, and 17.9 percent more trade seizures. There were even larger increases in trade remedy evasion investigations (106.4 percent), forced labor withhold release orders (116.7 percent), and WRO-related detentions (2600 percent). Many of these measures could see further increases in FY 2021, highlighting the need for importers to develop, implement, and monitor effective compliance programs.

To evaluate importer compliance and identify problems CBP frequently uses risk analysis and survey assessments. RASAs can subject importers to detailed scrutiny and require significant documentation as evidentiary support. If they reveal perceived compliance risks, RASAs may result in full-blown audits and enforcement actions may follow. Click here to register for ST&R’s April 28 webinar on the RASA process, the primary risk areas currently being targeted for RASA consideration, and how importers can better prepare to undergo a RASA or audit.

 

FY 2019

FY 2020

Completed audits

391

466

Collections from audits

$43.1 million

$44.6 million

Trade penalties issued

2,108

2,309

Trade liquidated damages

21,093

19,612

Collections from penalties and liquidated damages

$30.1 million

$20.1 million

Trade seizures

62,509

73,708

IPR seizures

27,599

26,490

MSRP of IPR seizures

$1.5 billion

$1.3 billion

Import safety seizures

6,280

8,208

Value of import safety seizures

$12.0 million

$12.7 million

EAPA investigations

31

64

Value/lost revenue identified in EAPA

$250 million

$287 million

Forced labor WROs

6

13

Detained shipments related to WROs

12

324

Value of cargo on WRO detentions

$1.2 million

$55.5 million

Copyright © 2021 Sandler, Travis & Rosenberg, P.A.; WorldTrade Interactive, Inc. All rights reserved.

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