Importer Self-Assessment Program (ISA)

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Presentation transcript:

Importer Self-Assessment Program (ISA)

Importer Self-Assessment (ISA) ISA is a voluntary trade facilitation partnership program for trade compliant companies that want to assume responsibility for managing their own compliance, in exchange for less CBP oversight.

ISA Benefits Exemption from Comprehensive Audits Coverage Available for Multiple Business Units ISA Consulting Team Compliance Assistance Risk Assessment Data Analysis Trade Data Profile Enhanced Prior Disclosure/Mitigating Factors Enhanced Trade Facilitation

ISA – Current Statistics 197 participants (751 different Importer of Record numbers) ISA participants represent approximately 16% of the total value imported in 2008. ISA participants were 99.4% compliant in 2007

The ISA Process Apply (Importer) Memorandum of Understanding ISA Questionnaire Responses Import Compliance Manual Self-Testing Plan

The ISA Process (cont.) Prepare Meet ISA Team (CBP) Importer Determine Areas for Review Select Walk-Through Entries Provide Agenda to the Importer Importer Prepare PowerPoint Slide Presentation Obtain Documentation for Walk-Through Entries (Purchase Order thru Payment) Meet 2-Day, On-Site Visit (aka Application Review Meeting) Presentation from the Importer Present Review Areas Using the Five Components of Effective Internal Controls (SAS 78) Provide a Walk-Through of Automated Systems Explain ISA Self-Testing Plan Walk-Through Transactions

The ISA Process (cont.) Wrap-Up ISA Team Documents the Meeting and Follows-Up with any Questions Internal Report Submitted to a Multi Displinanary CBP Review Board Annual Notification Letter Results of the Self-Testing Changes to the Customs Compliance Department and/or Personnel Changes in the Organization (e.g., Ownership, Acquisitions, Divestures, etc.) Utilization of Special Programs not Reviewed (e.g., NAFTA, Drawback, Drop Shipments, etc.)

Hurdles, Sand Traps, Roadblocks, & Pitfalls…Helpful Hints To Keep On Course: Incomplete ISA applications C-TPAT and ISA applications for different companies Using ISA as an FA escape route, rather than applying for ISA proactively Including multiple IR #s on one ISA application, when many and/or all of the IR #s pertained to divisions with differing procedures Internal Controls unwritten and/or lack documentary support Companies with previously unresolved issues

Hurdles, Sand Traps, Roadblocks, & Pitfalls…Helpful Hints To Keep On Course: Allowing a consultant/outside counsel to present the company’s controls. Not truly take ownership of the CBP compliance function and overly relying on the broker to handle CBP compliance matters. Not responding timely to ISA team’s requests for Post-ARM support documentation requests No post entry review or other testing done throughout the year.

Best Practices – Internal Controls Management Commitment Establish Compliance Goals Develop Formal Policies & Procedures Establish Training Programs Conduct Internal Control Reviews

Best Practices – Internal Controls Create a CBP Compliance Group Access to Executives for Needed Resources Develop Compliance Requirements for Suppliers Establish a Record Keeping Program Partner with Customs & Border Protection

CBP Contact Information Richard Wallio, Chief, Partnership Programs (202) 863-6508 Albert Queen, Trade Liaison, Partnership Programs (202) 863-6071 Anita Harris, Trade Liaison, Partnership Programs (202) 863-6069 Leon Sample, Field Director, Regulatory Audit Division (859) 331-9020 ext.101 Jeannie Maher, Senior Auditor, Regulatory Audit Division (859) 331-9020 ext. 112 Brent Rose, Senior Auditor, Regulatory Audit Division (859)331-9020 ext. 126 Customs Web-site: http://www.cbp.gov/xp/cgov/trade/trade_programs/trade_compliance/importer _self_assessment/