MOCK AUDIT: A Step by Step, Complete Walk Through a Focused Assessment – How to Manage and Prepare for an FA and Respond to CBP Requests During the Audit

December 4, 2014 8:30am

Junichi Gondai
U.S. Customs and Border Protection (San Francisco, CA)

Richard A. Mojica
Miller & Chevalier Chartered (Washington, DC)

Alex Ebarle
Assistant Field Director
U.S. Customs and Border Protection (San Francisco, CA)

This comprehensive and practical working session will provide you with a step-by-step guide to the Focused Assessment audit process. Through a comprehensive mock audit, experts will take you through an in-depth analysis of the entire process, and provide real life examples and insights on major pitfalls to avoid. Learn how to respond to auditor requests, and take away valuable tools that will help your company withstand the rigorous audit process. Benefit from case studies and make sense of methodologies that CBP uses during the audit process. Topics of discussion will include:

  • What is the “control environment” and what does CBP review prior to commencing an audit?
  • Answers which CBP deems as red flags in the importer questionnaire
  • Understanding how CBP reviews an importer’s risk assessment and the importance of acknowledging these risks upfront
  • Learning what CBP expects your compliance manual to include and how the manual is used in the audit process
  • Types of internal company communications CBP reviews to determine if there is adequate dialogue between relevant departments (e.g. logistics, licensing, legal, compliance)
  • How to prepare company officials for interviews with CBP
  • Determining the scope of resources to devote to the process
  • Examining how CBP chooses its “sample selection” of entries to audit
  • What to do when CBP finds an error: Quick Response, corrective action, internal controls
  • How does CBP respond when corrective action is not taken: Review of “statistical sample” (50-200 entries)
  • Key indicators that CBP plans to audit your company
  • Determining what to request from CBP once an audit has commenced
    • Timeframes and how to communicate
    • Request for confidential treatment
  • When to call in external counsel or other advisors
  • How to develop a compliance improvement plan