Compliance convergence can have several variations. I have written about the convergence from export controls to anti-corruption controls. Last week I wrote about the Lacey Act, which regulates imports of certain types of wood, among other items. One of the valuable lessons of compliance convergence can be the cross-over of lessons learned from one area of compliance to another. I was reminded of this when reading an article in the September issue of the ACC Docket, entitled “Import Loopholes Avoiding the Customs Audit” by Tiffany Jones. Her article discusses the “Importer-Self Assessment” (ISA) program initiated by the US Customs and Border Protection (CPB). The ISA has a requirement for a company to perform a “self-assessment” which means auditing, reporting results and correcting mistakes and implementing process improvements. This ISA relates to imports but it can be very useful for the Foreign Corrupt Practices Act (FCPA) compliance practitioner.