Background

U.S. Customs and Border Protection collected more money from importer audits, issued more penalties, and seized more imported goods in fiscal year 2021 over FY 2020, according to statistics recently made available by CBP. These increased enforcement actions highlight why now is a critical time to do an import compliance review.

The statistics below show increases in many customs enforcement measures in FY 2021. While the number of completed audits fell slightly, the amount of collections from those audits jumped 196 percent. There were 2.3 percent more IPR-related seizures and 11.4 percent more import safety seizures, but the value of those seizures soared 153 percent and 731 percent, respectively. There were fewer forced labor withhold release orders issued, but the number of WRO-related detained shipments was up 353 percent and the value of the cargo subject to those detentions was up 776 percent.

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 for ST&R’s on-demand 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

FY 2021

Completed audits

391

466

442

Collections from audits

$43.1 million

$44.6 million

$132.2 million

Trade penalties issued

2,108

2,309

2,394

Trade liquidated damages

21,093

19,612

19,834

Collections from penalties and liquidated damages

$30.1 million

$20.1 million

$21.7 million

Trade seizures

62,509

73,708

83,402

IPR seizures

27,599

26,490

27,105

MSRP of IPR seizures

$1.5 billion

$1.3 billion

$3.3 billion

Import safety seizures

6,280

8,208

9,145

Value of import safety seizures

$12.0 million

$12.7 million

$105.5 million

EAPA investigations

31

64

48

Value/lost revenue identified in EAPA

$250 million

$287 million

$392 million

Forced labor WROs

6

13

7

Detained shipments related to WROs

12

324

1,469

Value of cargo on WRO detentions

$1.2 million

$55.5 million

$486 million

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