In late 2016, U.S. Customs issued an unusual letter to a select group of 1000 U.S. importers containing numerous compliance publications and detailing facts about the importers’ highest-valued goods. The letter asks for the importers to review CBP’s laws and regulations, and to either assure compliance or disclose in advance any errors identified. It also asks that a receipt copy of the letter be returned. According to the CBP itself, the letter informally represents a warning that the importers are an audit target. The return of the letter, as Customs requests, provides proof of notice. Many importers are currently grappling with the decision to concede actual notice and ensure that they are in full compliance, or to decline to return and require such proof of notice from Customs in the event a deficiency in duty payments is later discovered.
Disclaimer: The article below appeared in the Fall, 2016 edition of The Beacon, the journal of the Maritime Exchange for the Delaware River and Bay, and is reprinted with permission.
For more information on this topic please click here to read the issued Client Alert.