Under the Customs Modernization Act of 1993, importers are responsible for using reasonable care when entering merchandise into the U.S.  U.S. Customs & Border Protection will often use audits as a means of measuring an importer’s internal controls over its import operations.  The most common audit is the Focused Assessment Audit which involves a review of an importer’s internal controls in the areas of Classification, Valuation, Free Trade Agreements, Antidumping, and other relevant areas. The Focused Assessment Audit is an extensive review of the importer’s records and documentation that pertains to its imported merchandise and the company’s system of ensuring compliance with all regulations and laws.  In order to substantiate internal controls, importers must at a minimum have documented Import Compliance procedures in place and be able to demonstrate to Customs that the procedures are followed.

The Law Offices of Paula M. Connelly has assisted numerous importers and exporters in preparing Import and Export procedures that will work for the company and will satisfy government requirements.

In addition to the Focused Assessment Audit, U.S. Customs can also perform smaller Quick Assessment Audits, Drawback Audits, and Free Trade Verification Audits.  Both the Bureau of Industry and Security and the State Department can also initiate audits of exporters to ensure compliance with the laws and regulations pertaining to export shipments.

It is crucial that companies retain experienced and knowledgeable counsel if notified of an impending audit.  Penalties can be assessed against companies if any material violations are discovered by the auditors

Protection and Representation for All Types of Audits

The Law Offices of  Paula Connelly can provide counseling and management for any type of Customs audit. Here are a few:

  • Focused Assessment Audits
  • Foreign Trade Zone Audits
  • Drawback Audits
  • Enforcement Audits
  • North American Free Trade Agreement  Audits
  • Free Trade Verification Audits

The Law Offices of Paula Connelly has helped numerous companies develop and manage an Import or Export compliance program and in drafting their own Import or Export manual. It is crucial that the procedures can be followed by the company and that they can substantiate this to the government when questioned.


The information contained in this Website is provided for informational purposes only, and should not be construed as legal advice on any subject matter.

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Law Offices of Paula M. Connelly
100 Trade Center
Suite 660
Woburn, MA 01801