Workshop B – Inside the New Realities of Preparing and Managing CBP Audits: A Deep Dive into Key Lessons Amid a Surge in CBP Audits, Detainment and Seizure of Goods

Oct 7, 2025 1:30 pm – 5:00 pm

  • Compliance: Adherence to statutes and import regulations
    • Establishing reliable measures to ensure imported goods are consistent with all requisite statutes and regulations
    • Establishing reliable procedures to ensure you are not importing goods in violation of any statutes and regulations including any active CBP withhold release order or finding
    • Obtaining a “ruling” from CBP regarding the admissibility of your goods and if so, have you established reliable procedures to ensure that you followed the ruling and brought it to CBP’s attention
    • Developing a reliable program or procedure to maintain and produce any required customs entry documentation and supporting information
    • Establishing a reliable procedure of having a third-party auditor familiar with evaluating social risks conduct periodic audits of your supply chain
  • Traceability: Implementation of a traceability program which includes an independent third-party audit mechanism and the ability to establish the source of imported products
    • Establishing a reliable procedure of conducting periodic internal audits of your supply chain
    • Establishing a reliable procedure of having a third-party auditor conduct periodic audits of each of the elements of your supply chain to validate being able to identify the risks of importing prohibited goods in your supply chain
    • Vetting new suppliers/vendors for through questionnaires or some other means for the risk of introducing prohibited goods into your supply chain
    • Adding a new supplier in your supply chain? Did you have a third-party audit take place prior to initiating supply?
    • Getting third-party auditors to provide an affidavit or certificate stating its (i.e., the third-party auditor’s) independence from you and your suppliers (other than the audit engagement itself)
  • Remediation: Remediation of any identified risk indicators that goods may be prohibited from importation into the U.S.
    • Demonstrating that you obtained a credible third-party audit and that you provided unfettered access to documentation, facilities, and personnel
    • Making sure remediation implementation is verified by the same third-party auditor