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. 

Forced Labor

Deleon Trade auditors work with its law firm partners to assist clients during UFLPA detentions, as well as interfacing with CBP to secure the release of the detained goods.  We also frequently work with companies' existing or new Forced Labor due diligence providers to design the UFLPA due diligence strategy and with procurement of personnel to understand existing supply chains and enhance supplier onboarding procedures.  We provider practical and actionable advice to help companies address their UFLPA risks efficiently and with minimal business disruption.

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. Customs.

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.

Customs Value Reconciliation Program

Reconciliation allows an importer to revise certain elements of an entry summary that were indeterminable at time of entry. We assist clients with multiple aspects of the reconciliation process including preparing value reconciliations covering transfer price adjustments, assists, royalties, maquiladora computed value, etc.

Complex Valuation Reviews

Where there are multiple sales of goods prior to their importation into the United States, the First Sale rule allows importers, in certain circumstances, to use the price paid in the “first or earlier sale” as the basis for the customs value of the goods rather than the price the importer ultimately paid for the goods. This rule can greatly reduce duties and fees paid by Importers. Our team of trained auditors conduct first sale valuation assessments to ensure importers meet the rule and develop strong internal controls to ensure future compliance.

Customs 101 & Customized Training

Deleon Trade staff has conducted multiple training sessions covering various import topics at large conferences and has hosted a US-Mexico Customs Compliance Conference in 2014, Advanced Topics in Customs Compliance Conference in 2016, and Advanced Topics in Customs Compliance Conference in September 2017 in Houston.  Please see our conference website at www.customsconferences.com for more details.  Our team has also provided numerous in-house training sessions, one-on-one training sessions, and on-the-job training.  Our dedication to quality education and creating unique networking environments is unsurpassed.

Broker Audits

Having updated compliance manuals, updated policies and procedures is critical but it is only a portion of what CBP will consider during a broker audit. Are you prepared to provide documentation that you are complying with ten factors of reasonable care as defined in the regulations?  Our team can help you prepare for a broker audit or help you make sure you are ready should you be selected for an audit. Our experts can help you identify areas of potential risk and give you proven guidance to shore up those risk areas.

HTS Tariff Classification

We assist clients with HTS classification needs across industries utilizing our experience, focus on detail and reasoned judgment to provide clients with robust classification solutions.  We can help you build a classification database, analyze your current database or simply help you with classifying a new product or component. Our experts can help you optimize opportunities afforded with current trade programs available as well as verify your products have been properly classified. 

Broker Compliance Manuals

We can help your brokerage set achievable yet meaningful objectives for compliance activities. We do this by tailoring a compliance manual that integrates your current company policies and procedures in a way that meets or exceeds standards and is least disruptive to your daily operations.  We can review your current company policies and procedures to ensure you have set proper compliance goals. With the ever-changing world of international trade, your manuals, policies and procedures should be reviewed and updated to keep up with these changes on a regular basis.