Importers: Changes to Focused Assessment

Importers: Changes to Focused Assessment

What is the Focused Assessment Program?

Comprehensive audits of importers that involve an assessment of internal control over import activities to determine if the importer poses an acceptable risk for complying with CBP laws and regulations comprising of three phases:

1. Pre-Assessment Survey (PAS)
2. Assessment Compliance Testing (ACT)
3. Follow-Up Audit

CBP has implemented updates to Importers Focused Assessment Program effective October 1, 2014 (early fiscal year 2015).

Reasons for the changes

• Adapt to changes in our environment that have occurred since the last major update impacting:
  • U. S. and world economies
  • CBP risk parameters and processes
  • Business practices
  • Company profiles
• Reflect the current (December 2011) Revisions of the Government Auditing Standards
• Incorporate 2013 COSO Internal Control – Integrated Framework [updated from 1992]

Impact – Four General Areas

• Increased emphasis on the consideration of significance/materiality in making audit decisions
• Expand guidance on tailoring the audit approach to suit the specific circumstances of the importer (no checklists)
• Replacing sample size matrices with more general sample size ranges
• Incorporated changes in report language 

Effective Date

• Plan to implement updated program for all new PAS assignments started on or after October 1, 2014
• This update only addresses the PAS [Pre-Assessment Survey] phase
• Reaching out to the trade community
  • Webinar: previously recorded – you can find here

For more information about Focused Assessments [FA]: CBP

*Stay tuned for another blog post on Focused Assessments changes: continuing the information regarding Pre-Assessment Survey (PAS) .