CBP Focused Assessments, Audits & Audit Surveys
CBP Regulatory Audit conducts many different types of Importer reviews. These can range from an Audit Survey to a full-blown
Focused Assessment. We prepare clients for each type of audit, explain what is to be expected, assist in responding to requests for information, and attend site visits while CBP is
present. There are many factors that should be considered to having a successful audit outcome. Our team of former Customs Auditors and Audit Supervisors have extensive experience and
know how to navigate these audits effectively.
Prior Disclosure Quantifications & Statistical Sampling
CBP regulations allow statistical sampling in the context of audits and Prior Disclosures (see 19 C.F.R. 163.11(c)). Our team of
former Customs Auditors and Audit Supervisors were trained by Customs on the same statistical sampling methods used by Customs. Statistical sampling requires a thorough understanding of
statistics, import data, and potential risk areas. Our Auditors assist clients in developing and implementing statistical sampling methods in order to satisfy U.S. Customs requests and
requirements. Statistical sampling is utilized to review an importer's Customs operations in an efficient manner without having to review one hundred percent of transactions. This
approach allows auditors to draw conclusions from data and is utilized to determine importer compliance with U.S. Customs laws and regulations and in computing any loss of revenue to U.S.
Import Compliance Manual & Standard Operating Procedure Development
Every importer’s compliance program, staffing, infrastructure, systems, risk areas, and level of complexity are different. As a
result, all compliance programs should not be designed in the same way. We assist importers in developing and implementing comprehensive U.S. Customs import compliance programs and manuals
that are tailored to their specific program and resources. Internal controls are critical in passing any type of U.S. Customs audit. During an audit, U.S. Customs expects the importer to
have written policies and procedures describing relevant detailed specific internal controls to ensure compliance in each risk area.
Risk Assessments & Post Entry Audits
How many times have you heard about internal controls? Ensuring that your company has a strong system of internal control that covers
all 5 components is critical to ensuring compliance and passing CBP audits. Our Auditors have had extensive formal training and experience in developing, testing, and evaluating systems of
internal control. Most importers miss the Risk Assessment component of internal control and do not effectively manage their limited resources in the areas that represent their greatest risk of
non-compliance. We assist importers in developing and implementing risk assessments (including macro-based ADD/CVD risk assessments) and comprehensive post entry audit programs. These
programs are designed to test the accuracy of import entry declarations filed with U.S. Customs by brokers and to identify discrepancies with customs laws and regulations. We also provide post
entry audit services on an "outsourced" basis where Deleon Trade handles all aspects of developing, implementing and running the program on behalf of a specific importer.
Free Trade Agreement Rule of Origin Analysis & Audits
Our team of former Customs Auditors and Audit Supervisors have had extensive training in free trade agreements while working for CBP (e.g.
NAFTA, GSP, Korea Free Trade, etc.). In addition, we have conducted NAFTA audits in the US, Canada and Mexico and have represented clients during NAFTA audits conducted by Mexican Customs
officials (we are fluent in Spanish). We have also assisted clients defend FTA claims during Focused Assessments and Quick Response audits. We assist clients on a regular basis perform
rule of origin analysis to ensure that products qualify under the specific rules of the free trade agreement.