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Importer Self-Assessment Program (ISA)

Importer Self-Assessment Program (ISA). 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. ISA Benefits.

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Importer Self-Assessment Program (ISA)

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  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 • ISA Team (CBP) • 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. 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 Hurdles, Sand Traps, Roadblocks, & Pitfalls…Helpful Hints To Keep On Course:

  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) 863-6508 • Albert Queen, Trade Liaison, Partnership Programs (202) 863-6071 • Anita Harris, Trade Liaison, Partnership Programs (202) 863-6069 • Leon Sample, Field Director, Regulatory Audit Division (859) 331-9020 ext.101 • Jeannie Maher, Senior Auditor, Regulatory Audit Division (859) 331-9020 ext. 112 • Brent Rose, Senior Auditor, Regulatory Audit Division (859)331-9020 ext. 126 Customs Web-site: http://www.cbp.gov/xp/cgov/trade/trade_programs/trade_compliance/importer _self_assessment/

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