Practices 
 

Audits

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U.S. Customs and Border Protection routinely uses two different types of importer audits, the Focused Assessment (“FA”) and the Quick Response Audit (“QRA”).

Focused Assessments


The FA employs a risk-based approach to assessing an importer’s compliance with Customs laws and regulations and involves a review of an importer’s internal controls and procedures to determine the likelihood of non-compliance. Importers with an unacceptable risk determination are subject to a comprehensive Customs audit. Any large volume importer can anticipate eventually being selected for a FA, as Customs tries to review all large importers every few years.

Quick Response Audits


A QRA, on the other hand, is a single issue audit with a narrow focus and is often the result of a referral to Customs Regulatory Audit from an import specialist or other Customs official that suspects an importer has a potential non-compliance issue that requires further evaluation.

When Customs perceives that there has been a specific violation or general lack of compliance, it can also commence a general audit of the importer. These audits can be very lengthy, detailed, and administratively expensive. Thus, continual attention to compliance is important.

While a Customs audit may appear very daunting for an importer, Barnes/Richardson has helped numerous clients throughout the entire audit process. For example, after the initial selection and contact from Customs, Barnes/Richardson can conduct a pre-audit compliance review to identify non-compliance issues for possible prior disclosure. At the conclusion of the audit, Barnes/Richardson can contest and/or file comments on the audit report findings. Although an importer’s accounting records play an integral role during a Customs audit, Barnes/Richardson is particularly suited to provide representation during a Customs audit as our firm includes a licensed Customs broker and a former certified public accountant. From start to finish, Barnes/Richardson can help.  

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