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CBP Announces Changes to Focused Assessment Process

U.S. Customs and Border Protection (CBP) advised that as of October 1st, changes have been adopted that address the way that focused assessments are conducted.  The changes to this program will bring the focused assessment process in line with current Government Auditing Standards and will place emphasis on significance and materiality while determining which areas to audit.   

The new program will involve the importer earlier in the process and will eliminate the need for a Formal Advance Conference. The “Internal Control Questionnaire” (ICQ) will be replaced with the “Pre-Assessment Survey Questionnaire” (PASQ). 
 
A risk assessment aligning with the current government auditing standards and adhering to the audit risk model will be conducted.  A “Pre-Assessment of Risk” (PAR) will then be determined based on the importer’s activity. The PAR will allow for evaluation of an importer while taking into account priority trade issues and identifying the greater areas at risk of non-compliance. 
 
CBP will then conduct a walk-through and interviews, where documented internal controls and written policies will be useful. There will be an emphasis on procedures for purchasing, receiving into inventory, making payments to vendors, and providing the declarations to CBP. Sample size matrices will be replaced with more general guidelines, allowing for more flexibility in testing. The sample size to be tested will depend on risk levels and may fluctuate depending on the circumstances.  
 
What can an importer do to prepare for these changes? First, a certain amount of attention should be paid to internal controls, focusing on demonstrating policies and ensuring procedures are adhered to and not simply documented.  Secondly, it is important that importers are fully aware of the focused assessment process and the requirements should they be selected. 
 
If you have any questions about this policy change, would like some assistance strengthening your import process, or are undergoing a focused assessment and would like assistance, please feel free to contact Allyn International at sales@allynintl.com.

 

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