The inaugural article in our International Trade, Enforcement & Compliance regulatory series, “What Every Multinational Organization Should Know About . . . Customs,” provided a list of Customs red flags and errors that we commonly see at major importers. Since then, we have received requests for a companion customs compliance checklist to help importers evaluate the strength of their customs compliance program and to provide guidance for companies looking to benchmark them against suggested best practices. To help with this task, we have put together this follow-up Customs compliance guidance.
The existence of an effective compliance program is one of the first items tested by U.S. Customs and Border Protection (CBP) in an audit. A proactive review of the compliance program is the starting point for enhanced customs compliance and should start with the following:
Your organization should consider whether there are customs strategies that can minimize duties.
Next, you should confirm that your organization has taken care of often-overlooked customs housekeeping issues.
All relevant personnel should receive periodic training on customs requirements. Relevant personnel to consider training include persons in charge of customs compliance, procurement personnel, and employees in the shipping/logistics departments. Some topics that training should cover include (1) how to classify goods, (2) how to interface with freight forwarders and customs brokers, (3) responsibilities of importers of record, (4) FTA/NAFTA responsibilities if preferences are being claimed, (5) how to determine country of origin, (6) recordkeeping responsibilities for imports and exports, and (7) screening responsibilities and other responsibilities when exporting.
Fill out our risk-assessment questionnaire, and our customs attorneys can help your organization assess its import-related risk. Click here to take the survey.