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.
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FY 2019
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FY 2020
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FY 2021
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Completed audits
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391
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466
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442
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Collections from audits
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$43.1 million
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$44.6 million
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$132.2 million
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Trade penalties issued
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2,108
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2,309
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2,394
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Trade liquidated damages
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21,093
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19,612
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19,834
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Collections from penalties and liquidated damages
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$30.1 million
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$20.1 million
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$21.7 million
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Trade seizures
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62,509
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73,708
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83,402
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IPR seizures
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27,599
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26,490
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27,105
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MSRP of IPR seizures
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$1.5 billion
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$1.3 billion
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$3.3 billion
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Import safety seizures
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6,280
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8,208
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9,145
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Value of import safety seizures
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$12.0 million
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$12.7 million
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$105.5 million
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EAPA investigations
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31
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64
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48
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Value/lost revenue identified in EAPA
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$250 million
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$287 million
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$392 million
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Forced labor WROs
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6
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13
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7
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Detained shipments related to WROs
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12
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324
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1,469
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Value of cargo on WRO detentions
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$1.2 million
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$55.5 million
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$486 million
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