Broker

1
Broker Vendor Oversight
2
ISA Benefits

• Exemption from Focused Assessment
• Coverage Available for Multiple Business Units
• Access to CBP Liaison(s)
• Summary Trade Data
• Enhanced Prior Disclosure/Mitigating Factors
• Enhanced Trade Facilitation

3
Responsibility

• Section 484 of the Tariff Act, as amended (19
  U.S.C. 1484), the importer of record is
  responsible for using reasonable care to enter,
  classify and determine the value of imported
  merchandise and to provide any other information
  necessary to enable U.S. Customs and Border
  Protection to properly assess duties, collect
  accurate statistics, and determine whether other
  applicable legal requirements, if any, have been
  met.

4
Best Practices Broker Oversight

• Standard Operating Procedure (SOP) with each
  broker identifying roles and responsibilities.
  For example
• Can the broker classify merchandise?
• Where does the broker obtain classification
  information?
• Can the broker act without consent of the
  company? If so, when?
• What reviews are conducted by the broker?
• What is reported to the company and when?
• What documentation must the broker have in order
  to make entry?

5
Best Practices Broker Oversight (cont.)

• Broker Scorecard
• Measure brokers qualitative and quantitative
  performance.
• Regularly scheduled meetings with broker to
  discuss performance and/or issues.
• Power of Attorney should be reviewed yearly.
• Designated representative at the brokerage
  assigned to the company.
• Utilize ACE or FOIA data to ensure only
  authorized brokers are making entry on your
  companys behalf.

6
Best Practices Vendor Oversight

• Vendor Compliance Manual
• Have each vendor confirm, in writing or
  electronically, that it agrees to follow your
  companys policies and procedures as laid out in
  the vendor compliance manual.
• Vendor Chargeback Program
• Charge vendors for mistakes that occur by not
  following your companys policies and procedures.
• On-site visits and/or audits of vendors
  facilities by your company or a designated
  representative.
• Scheduled and unscheduled visits/audits.

7
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
  [phone] ext.101
• Customs Web-sites
• http//www.cbp.gov/xp/cgov/trade/trade_programs/tr
  ade_compliance/importer _self_assessment/
• http//www.cbp.gov/xp/cgov/trade/legal/informed_co
  mpliance_pubs/