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.

Jul. 20, 2026: CBP's Section 232 Copper Smelt and Cast Reporting Requirements Guidance
Jul. 20, 2026: White House Introduces Section 338 Tariffs on Canadian Articles
Jul. 16, 2026: Commerce Department Publishes Rulemaking Docket: What's on the Chopping Block and What's Getting the Ol' College Try…. At Least for Now
Jul. 16, 2026: Long-Awaited Brazil 301 Duties Issued
Jul. 16, 2026: Trade Fraud Task Force Lays Out Tools it Intends to Use Against Fraud
Jul. 10, 2026: White House Declines Section 232 Tariff on Aerospace Articles
Jul. 2, 2026: CAPE Processing Restrictions for Warehouse Entries
Jun. 30, 2026: European Union Implements U.S. Trade Deal
Jun. 30, 2026: CBP Updates Vehicle Duty Offset Guidance
Jun. 30, 2026: PHASE 2: CBP Now Accepting Reconciliation Entries in CAPE
Jun. 18, 2026: United States Finds Forced Labor for Serbian Copper Producer
Jun. 16, 2026: Supreme Court Declines to Review HMTX Challenge to Section 301 Tariffs
Jun. 15,2026: CBP Releases Updated Guidance on Forced Labor Prohibition Enforcement
Jun. 10, 2026: E.U. May be Joining Others in Harder Line Toward China Trade
Jun. 9, 2026: Forced Labor Watchdog Barred from Suing U.S. Customs
May 27, 2026: Commerce and USTR Implement Section 232 Relief for Taiwan
May 26, 2026: CBP Ruling Clarifies Price Paid or Payable
May 26, 2026: CBP Updates CAPE Guidance for Entries Flagged for Reconciliation
May 13, 2026: And Suddenly, Shippers Have Choices
May 12, 2026: BIS Set to Publish Notice on Applications for Pharmaceutical Company-Specific Agreements
May 11, 2026: CBP Releases Updated Guidance on 232s for USMCA Medium and Heavy Vehicles
May 8, 2026: Court of International Trade Panel Strikes Down Section 122 Tariffs, Throws Out Most State Suits
May 4, 2026: U.S.& EU Align on Critical Minerals Supply Chain Resilience
Apr. 27, 2026: EU Commissioner Šefcovic on EU-U.S. Steel Talks
Apr. 24, 2026: Potential AD/CVD for Mexican, Vietnamese, & Thai Chassis
Apr. 24, 2026: CIT Decision Highlights CAPE Phase II IEEPA Refund Concerns
Apr. 21, 2026: CAPE Phase 1, Day One, Better Than Feared
Apr. 20, 2026: BIS Enforcement Action Against Coastal PVA Technology Signals Continued Scrutiny of EAR99 Exports
Apr. 20, 2026: CBP Updates Guidance on Jones Act Waiver
Apr. 14, 2026: CBP Publishes CAPE Phase 1 Update
Apr. 10, 2026: CBP Releases First CAPE IEEPA Refund Instructions
Apr. 2, 2026: Big Changes to Tariffs on Steel, Aluminum, Copper and their Derivative Articles
Apr. 1, 2026: CBP Publishes New Applications for ACE Portal Accounts
Mar. 31, 2026: CIT Potentially Broadens the Path for IEEPA Refunds—But the End Is Not Here Yet
Mar. 30, 2026: Section 232 Steel/Aluminum Content Reporting "Guidance"
Mar. 20, 2026: CBP Ruling Clarifies Customs Business, Addresses AI
Mar. 16, 2026: USTR Initiates Forced Labor Section 301 Investigation
Mar. 12, 2026: CBP Updates Court on IEEPA Refund Process and Technology
Mar. 12, 2026: Here Come the Section 301 Investigations
Mar. 11, 2026: AD/CVD Petitions Announced on Lithium Battery Chemicals from China
Mar. 10, 2026: Bills Introduced in House and Senate to Restrict Non-Resident Importers
Mar. 9, 2026: States Challenge Section 122 Tariffs
Mar. 6, 2026: Customs Proposes IEEPA Refund Process to Court
Mar. 4, 2026: CIT Orders Refunds; Appeal Likely
Mar. 2, 2026: IEEPA Case Expedited to CIT for Relief
Feb. 27, 2026: Wither De Minimis After the Supreme Court IEEPA Decision?
Feb. 27, 2026: New AD/CVD Petitions on Truck Bed Covers from China

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