Customs Broker Compliance – customs broker audit


CBP 7501 Example – Provide employee with copy of CBP 7501

Use as record/reference to input correct information into ACS

 Encourage Clients to develop Compliance Manuals


Factors to consider in a strong compliance system.

  1. Whether the company has performed a meaningful risk analysis. perform this
  2. The existence of a formal written compliance program.  have one
  3. Whether appropriate senior organizational officials are responsible for overseeing the export (applies to Import also) compliance program.  assess oversight by officer, document meetings
  4. Whether adequate training is provided to employees.  provide training and document
  5. Whether the company adequately screens its customers and transactions.
  6. Whether the company meets recordkeeping requirements.  check against requirement of Customs Regulations 111 and 163
  7. The existence and operation of an internal system for reporting import/export violations.    where have occurred document corrective actions
  8. The existence and result of internal/external reviews or audits.   document your record of audits
  9. Whether remedial activity has been taken in response to import/export violations. employee wrongful actions – document corrective actions taken

Focus on Training (Internal and External) 

                 Audit       (Internal and External)

Goal of Broker is to offer filing services “Customs Business” and also services promoting compliance in classification, valuation, admissibility and security (C-TPAT). *

*note CBP Audit has observed that Brokers should address this area (compliance and advice)

contact Clement Key, Gerald Maready, Retired FNISs, LCHB 704 664 1932

Customs Broker Audit insight

From 31 broker penalty cases

Clustered results

incidents of accounting and financial deficiencies (more than one type) 39+

not properly maintaining employee list     17+

powers of attorney 14+

responsible supervision and control 8+

failed recordkeeping general 6+

lots of other issues not listed at this time = Above indicates where brokers should focus attention and of course follow Customs Regulations especially Part 111


need manual, focus on training and internal reviews – exercise responsible supervision

import export compliance hts classification

CLASSIFICATION Best way is to have the HTS Index. Search with term and see if it is listed. Refer to the referenced HTS number(s). Apply the GRIs. GRI 1 will be applicable most of instances…but follow the other GRIs as applicable.

Retired FNIS Maready instructed on classification in Southeast U.s. Retired FNIS Key also taught. We are not the best but in that class. We can make you better and cut through the clutter.


Clement Key CHB License, Gerald Maready CHB License – both retired FNIS

704 664 2932 call we’ll help you to be better