Importer Self-Assessment Program (ISA)

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Importer Self-Assessment Program (ISA)
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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.

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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

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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

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The ISA Process

• Apply (Importer)
• Memorandum of Understanding
• ISA Questionnaire Responses
• Import Compliance Manual
• Self-Testing Plan

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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

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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.)

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Hurdles, Sand Traps, Roadblocks,
PitfallsHelpful Hints To Keep On Course

• 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

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Hurdles, Sand Traps, Roadblocks,
PitfallsHelpful Hints To Keep On Course

• Allowing a consultant/outside counsel to present
  the companys 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 teams requests for
  Post-ARM support documentation requests
• No post entry review or other testing done
  throughout the year.

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Best Practices Internal Controls

• Management Commitment
• Establish Compliance Goals
• Develop Formal Policies Procedures
• Establish Training Programs
• Conduct Internal Control Reviews

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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

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CBP Contact Information

• Richard Wallio, Chief, Partnership Programs
  [phone]
• Albert Queen, Trade Liaison, Partnership Programs
  [phone]
• Anita Harris, Trade Liaison, Partnership
  Programs [phone]
• Leon Sample, Field Director, Regulatory Audit
  Division [phone] ext.101
• Jeannie Maher, Senior Auditor, Regulatory Audit
  Division [phone] ext. 112
• Brent Rose, Senior Auditor, Regulatory Audit
  Division [phone] ext. 126
• Customs Web-site
• http//www.cbp.gov/xp/cgov/trade/trade_programs/tr
  ade_compliance/importer _self_assessment/