Anti-dumping and Countervailing Investigations

New Part 165 to Customs Regulations in September 2016 emphasizes enforcement on evasion. Also ties into political rhetoric on Free Trade Protection. Signifies some effort in this direction political or otherwise. Suggest that you assess countries (rank by activity) and see what dumping exists by the country and do risk assessment. There is no de minimis amount; if you have a commodity that is associated with an action you must deal with it. Our programs (import manual, export manual, itar manual) and support materials equip you to have effective compliance in these activities training and internal audit.

Import Export Compliance

United States of America v.
Trek Leather, Inc. and Harish Shadadpuri CFAC ruled that individuals can be charged in Civil cases for negligence in the introduction of entries of merchandise not exercising reasonable care. Whether fraud or civil you can be liable to substantial penalties. Exercising reasonable care consists of at least

Perform a Meaningful Import / Export risk analysis.
Have a formal written import / Export compliance program!
An officer must be responsible for overseeing the import / Export compliance program.
Adequate training must be provided for employees.
A company must adequately screen their customers and transactions.
Your company must meet the compliance program’s record keeping requirements.
The existence and operation of an internal audit system for reporting Import / Export violations must be in place.
Your company must keep on file the documented results of internal / External reviews or audits.
Proof of remedial activity that has been taken in response to import / Export violations.