CBP Audit Preparation
Jennifer Diaz was recently published in Bloomberg Law!
Copyright 2026 Bloomberg Industry Group, Inc. Reproduced with permission. CBP Audit Preparation.
Editor’s Note: CBP’s modern enforcement strategy extends well beyond reviewing individual entries at the port of entry. The agency has broad authority to review an importer’s compliance at any point after entry, and can do so months or even years after the goods were imported. Through audits, assessments, and importer site visits, the agency evaluates whether importers have established effective internal controls and are exercising the “reasonable care“ required under U.S. customs law. These reviews may be triggered by a variety of factors including identified compliance risks, anomalies in import data, or as part of routine enforcement initiatives.
Receiving notice of a CBP review can understandably create concern within an organization. However, many of these reviews are not initiated because CBP has concluded that violations have occurred; rather, they are designed to evaluate an importer’s compliance systems, identify areas of risk, and determine whether additional review or corrective action is warranted.
Companies that understand the purpose of these reviews and prepare before receiving notice are generally in a far stronger position than those attempting to organize years of customs records after CBP has already initiated contact.
CBP’s Audit and Assessment Tools
Not every CBP review follows the same process. The scope, objectives, and level of scrutiny vary depending on the type of review being conducted. While each review mechanism serves a distinct purpose, findings from an initial inquiry or assessment may prompt CBP […]
