1. Importer Self-Assessment Program (ISA)

2. 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.

3. 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

4. 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

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

6. 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

7. 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.)

8. 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

9. 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.

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

11. 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

12. CBP Contact Information
Richard Wallio, Chief, Partnership Programs (202)
Albert Queen, Trade Liaison, Partnership Programs (202)
Anita Harris, Trade Liaison, Partnership Programs (202)
Leon Sample, Field Director, Regulatory Audit Division (859) ext.101
Jeannie Maher, Senior Auditor, Regulatory Audit Division (859) ext. 112
Brent Rose, Senior Auditor, Regulatory Audit Division (859) ext. 126
Customs Web-site:
_self_assessment/