Over the past several months, importers have started to receive compliance letters from CBP’s Regulatory Audit Division. The letters remind importers of their obligation to exercise reasonable care in conducting their Customs business and identify a number of Informed Compliance Publications. CBP requests acknowledgment of receipt by a corporate officer, but we recommend our clients discuss with counsel whether to sign and return this acknowledgement.
These letters appear to be in response to changes brought about by the Trade Facilitation and Trade Enforcement Act of 2015, which included a mandate to CBP for improved enforcement. In a recent post, GDLSK, a top Customs law firm, provided their perspective and additional information regarding the CBP compliance letters. While opinions are divided over what actions Customs may take in light of these communications, we urge you not to ignore them and to review your compliance program for weaknesses. If you have yet to receive such a letter, this may be the appropriate time to review your compliance program if you have not done so recently.
Deringer’s Consulting Group stands ready to discuss your specific situation, answer your questions, or assist with a review of your current system culminating with a written report of our findings with suggestions for improvement where necessary. To speak with a highly qualified Customs Compliance expert at Deringer, please contact us via email at firstname.lastname@example.org or call us at (518) 298-8281 (Champlain, NY) or (734) 641-6852 (Romulus, MI).