Audits, Penalties, Other Customs Enforcement Efforts See Uptick in FY 2020

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

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