cbp pre-audit assessment questionnaire
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- 1. CBP PRE-ASSESSMENT IMPORT AUDIT QUESTIONNAIRE Presented by Brent Claypool, LCB/CCS To avoid any penalties, it's essential American Importers have written procedures that comply with U.S. Customs and Border Protection (CBP) Regulations. Complete the following CBP Pre-Assessment Import Audit Questionnaire and save in it Microsoft Word Document or PDF file format, which enables your Company to identify all non- compliant areas related to its imported merchandise, and to allow your Company to implement its written Import compliant procedures to prevent and/or mitigate your Company from receiving any CBP-issued non-compliant regulatory penalties. CONTACT INFORMATION Name(s) of the person(s) completing the form: If there are multiple preparers, your company should identify a single person with whom the CBP Audit team should contact to clarify the companys answers. Title(s): Phone Number(s): E-mail Address(s): Section 1 Information about (name of Importers) organization and policy and procedures related to CBP activities. 1.1 Describe your Companys Mission Statement, Code of Ethics/Conduct, and your Companys Objectives.
- 2. 1.1.1 How is the Mission Statement, Code of Ethics/Conduct, and your Companys Objectives communicated within your organization? 1.2 Who is responsible for assessing the risks to achieving your Companys Objectives? Identify if there is a sub- Group or individual responsible for assessing your Companys risk for being non-compliant with CBP Laws and Regulations. 1.2.1 Describe how the Risk Assessment is accomplished. For example, identify when, how, and how often the Risk Assessment is performed, what information is used, and what tolerances your Company considers to be acceptable. 1.2.2 When was the last Risk Assessment your Company performed? Describe any significant changes that your Company made as a result of its last Risk Assessment. 1.3 Within your Company, who has the overall responsibility for ensuring compliance with CBP Laws and Regulations?
- 3. Identify if there is an import function or department and describe your Companys chain of command (for example, identify to whom they report). If on the other hand your Company contracts its Import Compliance to a Customs Broker, Customs Consultant, or to another Outside Agent, identify them, and identify whom within your Company (for example, individuals or groups) is/are responsible for interacting with the Customs Broker, Customs Consultant, or to another Outside Agent (for example, providing information to them and monitoring their work). 1.3.1 If there is an import function or department, identify the following information: How is it staffed? Identify if an individual is assigned as the manager and identify the number of employees that report to them. How long has the manager been at his or her position? What are the managers responsibilities and how is the manager accountable? Identify if the manager is responsible for providing Weekly Activity Reports and describe any performance measures.
- 4. 1.3.2 If your Companys Import Compliance is handled by a Customs Broker, Customs Consultant, or another Outside Agent (for example, your Company doesnt have an import department), identify the following information: How long has your Company used the current Customs Broker, Customs Consultant, or another Outside Agent? Identify the processes your Company uses to com- municate information, and to monitor their work? Describe if your Company has a Written Agreement or Contract with its current Customs Broker, Customs Consultant, or another Outside Agent. 1.4 Whom at your Company is responsible for developing and maintaining the written policies and procedures implemented to ensure your Companys import compliance with CBP Laws and Regulations? How frequent are your Companys written policies and procedures updated?
- 5. Section 2 Information about the valuation of imported merchandise. 2.1 What is the Appraisement method used in your Companys imported merchandise valuation? 2.2 Who is responsible at your Company for transacting with its Foreign Vendors? Identify all Company individuals, groups, or departments that are responsible. 2.2.1 Describe how your Company negotiates its transactions with its Foreign Vendors? Identify all processes used and the applied conditions. 2.2.2 Describe the Terms of Sale used? If there are different Terms of Sale, identify the conditions for each Terms of Sale applied. 2.2.3 If applicable, describe the terms/conditions when your Company applies discounts or rebates?
- 6. 2.2.4 If applicable, describe any additional expenses such as Management Fees or Engineering Services that are separately billed by the Foreign Vendors? 2.2.5 What documentation shows the Terms of Sale and prices (for example, contracts, distribution and other similar agreements, invoices, purchase orders, bills of lading, proof of payment, correspondence between the parties, and Company reports or catalogs/brochures)? 2.3 Describe your Companys accounting procedures for recording purchases and payments. What Company accounts are used to record purchases of Foreign merchandise? Identify or provide a list of Vendor Codes. What Company accounts are used to record payments made to Foreign Vendors? Describe the payment methods used (for example, wire transfer, letters of credit). 2.4 If applicable, what Company accounting data/reports are provided to the Companys import function or department? Identify how often the Company data/reports are provided (for example, quarterly
- 7. reports of Price Adjustments for purchases from Foreign Vendors). For risk pertaining to related party transactions. 2.5 Describe the nature of the relationship between your Company and the related Foreign Vendor/Seller? Identify if your Company is the exclusive U.S. Importer. 2.5.1 Identify any financial arrangements (for example, loans, financial assistance, and expense reimbursement) between your Company and the Foreign Vendor/Seller? 2.5.2 If applicable, explain the terms and conditions of goods sold to your Company on consignment. 2.5.3 Describe how prices between your Company and the Foreign Vendor/Seller/Manufacturer are determined? Identify all sources of data used and, where appropriate, describe the applied accounting methodology or computational formulas. If Transaction Value is used, identify if your Company supports circumstances of sale or test
- 8. values. If applicable, provide the following information: Describe when Price Adjustments are made. Identify any additional expenses such as Management Fees or Engineering Services that are separately billed to your Company. 2.5.4 Explain how your Company accounts for its transactions? Identify if your Company maintains its own accounting books and records. 22.214.171.124 What are the intercompany accounts your Company uses? For risk pertaining to statutory additions. 2.6 Assists
- 9. 2.6.1 If applicable, identify the type of Assists that are provided to the Foreign Vendors for free or at a reduced cost (for example, tooling, hangtags, art or design work). 2.6.2 Within your company, who determines that the Assists will be provided? Identify all Company individuals, groups, or departments that are involved in the decision. When is it decided that the Assists will be provided? What Company accounts are used to record the costs of the Assists? 2.6.3 Describe the Company procedures used to ensure the Assist costs are included in the values declared to CBP. Identify whom at your Company decides how the actual Assist cost will be apportioned to the imported items, and also describe how the apportioned cost is tracked.
- 10. 2.7 Packing 2.7.1 If applicable, describe the Packing type (for example, Labor or Materials), Containers (exclusive of Instruments of International Traffic), and Coverings of whatever nature that is paid separately to the Vendor to put your Companys imported merchandise in condition ready for shipment to the United States. 2.7.2 Whom at your Company determines that the Packing cost will be separately charged? Identify all Company individuals, groups, or departments that are involved in the decision. When is it decided that Packing cost will be separately charged? What Company accounts are used to record the costs of Packing, Containers, and Coverings? 2.7.3 Describe the Company procedures used to ensure the Packing cost is included in the declared values to CBP.
- 11. 2.8 Commissions 2.8.1 If applicable, identify the Terms of Sale with Foreign Vendors that require your Company to separately pay for Selling Agent Commissions. Identify the Vendors. 2.8.2 Whom at your Company determines that Selling Agent Commissions will be paid directly to the intermediary? When is it decided that the Selling Agent Com- missions will be paid directly to the intermediary? What Company accounts are used to record the payment of these Commissions? 2.8.3 Describe the Company procedures used to ensure these Commissions are included in the declared values to CBP.
- 12. 2.9 Royalty and License Fees 2.9.1 If applicable, describe the Terms of Sale with Foreign Vendors that require your Company to pay, directly or indirectly, any Royalty or License Fees related to the imported merchandise as a condition of the sale of the imported merchandise for exportation to the United States. Identify the Vendors. 2.9.2 Whom at your Company determines that Royalty or License Fees will be paid as a condition of the sale? When is it decided that Royalty or License Fees will be paid as a condition of the sale? What Company accounts are used to record the payment of the Royalty or License Fees related to imported merchandise?
- 13. 2.9.3 What Company procedures ensure that Royalty or License Fees are included in the declared values to CBP? 2.10 Proceeds of Any Subsequent Resale, Disposal, or Use 2.10.1 If applicable, de
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