US Customs Compliance
U.S. Customs' COMPLIANCE Assessment TEAM Audit Information
The following information has been taken directly from the U.S. Customs Service Office of Strategic Trade Regulatory Audit Division. It represents the Compliance Assessment Team Documents or the CAT KIT. The purpose is to familiarize importers with the structure of the CAT audit. It is hoped that publishing this information will assist importers to maintain compliance with Customs Regulations.
INTRODUCTION
The passage of the Customs Modernization Act (Mod Act) in 1993 provided the framework for a partnership between the importing public and Customs. Under the Mod Act, Customs and the importer share the responsibility for compliance with trade laws and regulations. The importer is responsible for declaring the value, classification and rate of duty applicable to entered merchandise and Custom is responsible for informing the importer of his rights and responsibilities under the law.
Customs is committed to providing the importer with all the information needed to be incompliance with Customs laws and regulations. To fulfill this commitment, Customs is making available on its Web Site (www.customs.gov), the documents commonly referred to as the CAT KIT.
They are the same handbooks, audit program, sampling plans and guidelines that Regulatory Auditors and other Customs specialists on the Compliance Assessment Team (CAT) use to conduct a compliance assessment and follow-up. Providing the CAT KIT to the trade is intended to help importers prepare for a compliance assessment and conduct assessments of the company’s own Customs systems.
The index (on the opposing page) should allow the user to select the other CAT Kit files as needed. The documents most frequently requested from Customs by importers are the audit program, Exhibit 2, which includes the detailed audit steps used to conduct a compliance assessment and Exhibits 3 through 18, the statistical sampling matrices, used to test individual trade areas.
Each matrix includes the criteria, sampling universe, and what constitutes an error for a trade area, (e.g. quantity, classification, etc.) and describes how errors are evaluated. The titles of other exhibits are self-explanatory.
DOCUMENTS REQUIRED FOR A COMPLIANCE ASSESSMENT
NOTE: These documents supercede the CAT KIT dated May 1997. This CAT KIT contains 36 documents (exhibits). Some of the CAT KIT exhibits in the May 1997 version were obsolete and have been removed. Other exhibits have been added. Most exhibits have been updated and beginning with exhibit 22, many of the documents have been renumbered. The most significant changes in the CAT KIT are listed below:
- Audit Program
- Deleted Harbor Maintenance Fees
- Added Special Duty Provisions (9802, GSP, CBI, NATA, etc.) test in "Common Checks"
- Established $10 million threshold for reviewing most "Conditional Checks"
Sampling Plans
- Added sampling plans for GSP, CBI, ADD/CVD
- Changed sampling parameters for all trade areas except transshipment
- Precision used for sample selection changed from + 3% to + 5% (sample size reduced from 220 to 100)
- Attribute estimation sampling (rather than discovery sampling) now used for conditional checks
Materiality Policy
- Revised to cover conditional checks and computed value
- Changed "unreported" transaction value by establishing the materiality criteria as a dollar threshold