Audits

Overview
News
Articles

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

In a FA Customs employs a risk-based approach to assessing an importer’s compliance with customs laws and regulations. The FA starts with a review of an importer’s internal controls and procedures to determine the likelihood of non-compliance. Importers that represent an an unacceptable risk may be subject to a more comprehensive audit, a Compliance Improvement Plan, and follow up audits. Any large importer can anticipate being selected for a FA, as Customs tries to review all large importers every few years.

Quick Response Audits

A QRA is a single-issue audit 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 non-compliance issue that requires further evaluation.

Full Audits

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.

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. 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.

May 1, 2025: A Brief Survey of the IEEPA Legal Challenges
Apr. 30, 2025: CBP Clarifies: In-Transit Tariff Exemption Applies Only to Vessel Shipments
Apr. 29, 2025: Administration to Ease Auto and Parts Tariffs
Apr. 29, 2025: Latest Executive Order Limits Tariff Stacking
Apr. 24, 2025: De Minimis Ending for Goods of China (and Hong Kong)
Apr. 23, 2025: Section 232 Takes on Medium and Heavy-Duty Trucks
Apr. 17, 2025: Another Rapid Response Mechanism Request on the Books
Apr. 16, 2025: Trump Orders National Security Investigation for Critical Minerals
Apr. 10, 2025: EU to Pause Countermeasure Response for 90 Days
Apr. 9, 2025: EU and China Strike Back with Tariffs on U.S. Imports
Apr. 9, 2025: Trump Announces 90-Day Pause on Country-Specific Reciprocal Tariffs
Apr. 8, 2025: Customs Issues "Reciprocal Tariffs" Guidance
Apr. 8, 2025: White House Indicates China Will Face (at least) 104% Duties
Apr. 4, 2025: Tariff Subheading Guidance for ‘Reciprocal Tariffs' Published
Apr. 4, 2025: Global Response to U.S. ‘Reciprocal Tariffs'
Apr. 3, 2025: Correction and Exclusions for ‘Reciprocal Tariffs' Published
Apr. 2, 2025: Trump Announces 25% Tariff on Passenger Vehicles, Light Trucks, and Auto Parts
Apr. 2, 2025: Changes to De Minimis Duty Free Treatment for Good from China and Hong Kong
Apr. 2, 2025: Reciprocal Tariffs Announced
Mar. 27, 2025: President Trump Announces 25% on Autos and Light Trucks
Mar. 25, 2025: 25% Tariffs on Countries that Import Venezuela Oil
Mar. 19, 2025: AD/CVD Petitions Filed for Corrugated Boxes from China and Vietnam
Mar. 13, 2025: Countries Around the World Strike Back at the Trump Administrations Increase in Tariffs
Mar. 11, 2025: U.S. Seeking Broad Trade Agreement with India
Mar. 11, 2025: As Tariffs Loom, Steel and Aluminum Rules Remain in Flux with Lost Exclusions and Increased Duties
Mar. 11, 2025: CBP Guidance on Duties on Imports of Steel and Steel Derivative Products
Mar. 11, 2025: CBP Guidance on Duties on Imports of Aluminum and Aluminum Derivative Products
Mar. 11, 2025: Canadian 50% Steel & Aluminum Tariff Reportedly Averted
Mar. 11, 2025: Steel & Aluminum Derivatives Tariffs Outside Chapters 73 & 76 Effective This Week
Mar. 10, 2025: USTR Announces 2025 Trade Agenda
Mar. 6, 2025: Tariff Exemptions on Mexican USMCA Imports Reported
Mar. 6, 2025: All USMCA Imports Reportedly Exempt from Tariffs
Mar. 6, 2025: USMCA Tariff Exemption Executive Orders Published
Mar. 5, 2025: Senators Revise Plan to Tie Duties to Carbon Emissions
Mar. 5, 2025: Tariffs on Autos Under USMCA from Canada or Mexico Reportedly Suspended One Month
Feb. 4, 2025: Steel and Aluminum: The Gifts That Keep on Giving
Mar. 3, 2025: Timber, Lumber, and Derivatives Get Their Own National Security Investigation
Mar. 3, 2025: Canada and Mexico Duties Deadlines Arrive with No Indications of Delay
Feb. 28, 2025: Trump Indicates Likely March 4, 2025 Duty Increases
Feb. 26, 2025: Updated Guidance on Additional Duties for Imports from China and Hong Kong
Feb. 26, 2025: Copper Gets Its Turn for National Security Treatment
Feb. 24, 2025: Indictments Handed Down in Export Scheme
Feb. 24, 2025: The Next Shoe to Drop? USTR Proposes Actions Against Chinese Ships
Feb. 18, 2025: Preliminary ITC AD/CVD Determinations on Erythritol
Feb. 13, 2025: Trump Announces Marching Order for "Reciprocal Tariffs"
Feb. 11, 2025: Important Changes to Steel and Aluminum Imports into the United States
Feb. 11, 2025: Details Regarding New Aluminum Tariffs

View Archive

Jan. 22, 2025: Webinar: What We Know After the Inauguration
Sep. 9, 2024: McPherson to Co-Moderate Export Enforcement Discussion
Jun. 2, 2023: BRC and Attorneys Ranked in 2023 Chambers Guide
September 20, 2013: Barnes/Richardson Partner Cortney O'Toole Morgan to Speak at ACI's U.S. Customs Compliance Boot Camp
Dec. 12, 2012: Why Sound Due Diligence Is Crucial in Global Business
By: Brian F. Walsh and David G. Forgue
Dec. 14, 2012: Barnes/Richardson Partners Author Article on Trade Law and Due Diligence