One of the significant developments in US Customs and Border Protection’s (CBP’s) efforts to partner with the trade community is its development of a voluntary program, known as the Importer Self-Assessment (ISA) program, which allows importers who demonstrate strong internal controls over import activities and who regularly test their customs compliance to avoid being subjected to comprehensive customs audits, or Focused Assessments. A Focused Assessment can be one of the more unpleasant experiences to which an importer can be subjected. Focused Assessments can be lengthy, expensive and highly disruptive to a company’s business operations. Fortunately, according to a Federal Register Notice published on October 5, 2012, importers who have recently undergone a Focused Assessment can take advantage of the ISA program while bypassing some of its application requirements.

Importers who participate in the ISA program receive a variety of valuable benefits, including removal of the company from CBP’s audit pool, i.e., no more Focused Assessments; “front of the line” treatment for cargo release and consultation on internal advice requests; assignment of a national case manager to answer or direct issues, concerns or questions; and advance warnings of possible reasonable care violations, to allow the company to investigate and, potentially, file a prior disclosure. CBP is also making ISA membership a prerequisite for involvement in the new Centers of Excellence and Expertise covering select industries. Despite these benefits, membership by importers in the ISA program has not been as strong as CBP has hoped.