U.S. Customs and Border Protection targeted more import entries for forced labor concerns in fiscal year 2022 but saw declines in many other enforcement statistics from the previous year, according to statistics the agency recently made available. While these numbers are somewhat encouraging, CBP is still paying close attention to compliance issues and importers are therefore well-advised to conduct their own import compliance reviews to avoid problems in the future.
The statistics below show decreases in virtually all customs enforcement measures in FY 2022, compared to a number of significant increases in FY 2021. In FY 2022 the only increase was a 63.2 percent jump in the number of forced labor entries targeted, even as the value of such entries fell 4.1 percent. Other notable declines include 41.2 percent in collections from audits, 51.0 percent in import safety seizures and 40.9 percent in the value of such seizures, and 27.1 percent in Enforce And Protect Act investigations.
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 more information on ST&R’s related services.
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FY 2020
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FY 2021
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FY 2022
|
|
Completed audits
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466
|
442
|
430
|
|
Collections from audits
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$44.6 million
|
$132.2 million
|
$77.7 million
|
|
Trade penalties issued
|
2,309
|
2,394
|
2,121
|
|
Trade liquidated damages
|
19,612
|
19,834
|
18,667
|
|
Collections from penalties and LDs
|
$20.1 million
|
$21.7 million
|
$19.3 million
|
|
Trade seizures
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73,708
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83,402
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46,111
|
|
IPR seizures
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26,503
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27,115
|
20,813
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|
MSRP of IPR seizures
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$1.3 billion
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$3.3 billion
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$2.9 billion
|
|
Import safety seizures
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9,382
|
9,145
|
4,484
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|
Value of import safety seizures
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$21.6 million
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$105.5 million
|
$62.4 million
|
|
EAPA investigations
|
64
|
48
|
35
|
|
Value/lost revenue identified in EAPA
|
$215 million
|
$112 million
|
$97 million
|
|
Forced labor WROs
|
13
|
7
|
6
|
|
Forced labor entries targeted*
|
314
|
1,469
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2,398
|
|
Forced labor entry value
|
$49.8 million
|
$486 million
|
$466 million
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* In general, targeted entries are those that CBP has determined may be subject to a withhold release order or finding, or to the rebuttable presumption under the Uyghur Forced Labor Prevention Act, and thereby prohibited from importation into the U.S. CBP stops goods on targeted entries from entering the U.S. and requires further scrutiny of the importation.
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