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Develop unique self-testing plans for import risk factors. Follow frequency and tools for effective risk assessment. Maintain results for reporting and review.
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Self-Testing Plans • Unique to each company based upon risk factors associated with its business, process & procedures, and commodities. • Must be documented and submitted with as part of the Importer Self-Assessment (ISA) application package.
Example Risk Factors to Consider • Number of Customs brokers utilized • Classification of merchandise • Valuation methodology • Related party transactions • Additional payments (e.g., assists, royalties, undeclared payments) • Special trade programs • New employees, Customs brokers, special trade programs, etc. • Imports subject to other government agencies
Frequency of Reviews • Daily • Monthly • Quarterly • Annually
Review Tools • Risk Assessment / Risk Matrix • Transactional Testing • Statistical • Non-Statistical
Questions to Consider & Document • Will a risk assessment/risk matrix be used in conjunction with transactional testing? • Frequency of review (i.e., daily, monthly, quarterly, and/or annually)? • Who will conduct the review? • Note: Individuals should NOT be reviewing their own work. • How many items will be reviewed? • What areas (e.g., classification, valuation, special trade programs, other government agencies, etc.) will be included in the review and how will the areas be tested? • How will the reviewed items be tracked? • How will errors be handled? • Who will the results be reported to?
Self-Testing Results • Should be maintained for a 3-year period. • Should be available for review by your Account Manager and/or the ISA team upon request as part of the annual notification process. • Should be reported, at a high level summary, to U.S. Customs and Border Protection as part of the company’s Annual Notification Letter.
CBP Contact Information • Richard Wallio, Chief, Partnership Programs (202) 863-6508 • Albert Queen, Trade Liaison, Partnership Programs (202) 863-6071 • Anita Harris, Trade Liaison, Partnership Programs (202) 863-6069 • Leon Sample, Field Director, Regulatory Audit (859) 331-9020 ext.101 Customs Web-site: http://www.cbp.gov/xp/cgov/trade/trade_programs/trade_compliance/importer _self_assessment/