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Broker & Vendor Oversight. ISA Benefits. Exemption from Focused Assessment Coverage Available for Multiple Business Units Access to CBP Liaison(s) Summary Trade Data Enhanced Prior Disclosure/Mitigating Factors Enhanced Trade Facilitation. Responsibility.
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ISA Benefits • Exemption from Focused Assessment • Coverage Available for Multiple Business Units • Access to CBP Liaison(s) • Summary Trade Data • Enhanced Prior Disclosure/Mitigating Factors • Enhanced Trade Facilitation
Responsibility • Section 484 of the Tariff Act, as amended (19 U.S.C. 1484), the importer of record is responsible for using reasonable care to enter, classify and determine the value of imported merchandise and to provide any other information necessary to enable U.S. Customs and Border Protection to properly assess duties, collect accurate statistics, and determine whether other applicable legal requirements, if any, have been met.
Best Practices – Broker Oversight • Standard Operating Procedure (SOP) with each broker identifying roles and responsibilities. For example: • Can the broker classify merchandise? • Where does the broker obtain classification information? • Can the broker act without consent of the company? If so, when? • What reviews are conducted by the broker? • What is reported to the company and when? • What documentation must the broker have in order to make entry?
Best Practices – Broker Oversight (cont.) • Broker Scorecard • Measure broker’s qualitative and quantitative performance. • Regularly scheduled meetings with broker to discuss performance and/or issues. • Power of Attorney should be reviewed yearly. • Designated representative at the brokerage assigned to the company. • Utilize ACE or FOIA data to ensure only authorized brokers are making entry on your company’s behalf.
Best Practices – Vendor Oversight • Vendor Compliance Manual • Have each vendor confirm, in writing or electronically, that it agrees to follow your company’s policies and procedures as laid out in the vendor compliance manual. • Vendor Chargeback Program • Charge vendors for mistakes that occur by not following your company’s policies and procedures. • On-site visits and/or audits of vendors’ facilities by your company or a designated representative. • Scheduled and unscheduled visits/audits.
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-sites: http://www.cbp.gov/xp/cgov/trade/trade_programs/trade_compliance/importer _self_assessment/ http://www.cbp.gov/xp/cgov/trade/legal/informed_compliance_pubs/