Importers may be looking for ways to lower costs and take shortcuts in today’s environment of soaring costs and supply chain snarls, but doing so in the area of trade compliance could have a devastating impact. That was the message Daryl Moore, ST&R’s vice president, customs audits and partnership programs, had for attendees at the recent Columbus Logistics Conference.
U.S. Customs and Border Protection’s efforts to enforce trade laws and regulations have always included a focus on what it calls its priority trade initiatives, Moore said. These include AD/CV duties, trade agreements, intellectual property rights, import safety, agriculture, textiles and apparel, and revenue, including the collection of billions of dollars’ worth of Section 201, Section 232, and Section 301 tariffs. Today, CBP’s enforcement efforts also extend to the prohibition on imports of goods made with forced labor, sanctions against Russia and Belarus, and other measures.
These efforts are having a noticeable impact on importers, Moore noted. Between 2018 and 2021 trade-related penalties and liquidated damages imposed by CBP were up 40 percent, and from 2019 to 2021 the number of CBP audits increased by 13 percent and the amount collected as a result of those audits jumped 207 percent. Penalties, seizures, and cargo detentions have also accelerated in recent months.
Moore said importers should therefore be taking steps to (1) identify the types of risk they face, which can include everything from the type of product, to the country of origin and manufacturer, to the nature of the sales transaction, and (2) manage those risks by meeting CBP’s reasonable care standards, which can include consulting a customs expert, establishing effective internal controls, and conducting proactive compliance reviews.
Sandler, Travis & Rosenberg professionals are qualified customs experts skilled at helping importers identify and address compliance issues before they become problems. ST&R also offers an in-depth import compliance review that will test your company’s import-related internal controls and procedures against CBP standards and deliver a confidential report that will guide your compliance team toward industry best practices and concrete cost-savings measures.
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