CBP focused assessment: what it checks and how to run the same tests on your own entries first

What is a focused assessment?

CBP describes the Focused Assessment Program as a comprehensive audit that assesses the importer's internal control over its import activities, to determine whether the importer poses an acceptable risk for complying with CBP laws and regulations. It is run by Trade Regulatory Audit, the field offices CBP says use a risk-based approach and often work from a referral, and it has three possible phases:

1. Pre-Assessment Survey. CBP's published audit program for this phase (Exhibit 2C, October 2014) and its questionnaire (Exhibit 2A) are the documents the auditors work from. The survey looks at how the importer's processes produce its entries.
2. Assessment Compliance Testing. Exhibit 2C says this phase is performed as necessary for areas the survey found to represent an unacceptable risk; the auditors test more transactions to measure a compliance rate or quantify the lost revenue.
3. Follow-Up Audit. Performed as necessary to verify the corrective action the importer took on the control weaknesses found, and, where the importer tested itself, to validate its figure for the lost revenue.

CBP's audits page separates this from two other things that can arrive on the same letterhead. Other audits by Trade Regulatory Audit have a very specific objective rather than a broad one. Risk Analysis and Survey Assessments are not audits but nonaudit professional services under 19 U.S.C. 1509(a), used to evaluate a company on one issue quickly; the company receives a letter describing the outcome of the transactions reviewed, not a formal report.

The legal frame for all of them is 19 U.S.C. 1509. Paragraph (a) lets CBP examine any record relevant to determining the correctness of an entry or liability for duties, on reasonable notice and with the record described with reasonable specificity. Paragraph (b) sets the procedure for a regulatory audit: an estimate of the time required, an entry conference, a closing conference with preliminary results, and a written report within 90 days of the closing conference. Paragraph (g) sets penalties for failing to produce a record on lawful demand, and allows CBP to liquidate or reliquidate at the general rate where the missing record concerned a claim for a special rate of duty. The CBP page and the statute between them say what is tested and how; neither publishes durations for the phases or a selection formula, and this page does not invent them.

One group of importers is outside the program. CBP's Trade Compliance Handbook (version 5.0, December 2025) lists exemption from focused assessments among the benefits for partners in the CTPAT Trade Compliance program: accounts accepted into it are removed from Trade Regulatory Audit's pool for focused assessments, though they may still face a single-issue audit on a specific concern. The same handbook lets an importer that has come through a focused assessment as an acceptable risk within the last 12 months apply to Trade Compliance with a self-testing plan.

What does the audit test, box by box on Form 7501?

An internal-control audit asks whether the importer's process reliably produces a correct entry. The evidence it works from is the same data an importer holds: the entry summary, the commercial invoice, the packing list, the bill of lading, the certifications of origin, the product master and the purchase ledger. Mapped to the columns of CBP Form 7501 that Form 7501 field by field explains, the areas look like this.

The right-hand column is a description of a post-entry audit. The same checks, run on every line rather than a sample, are set out in the post-entry audit pillar; the value column depends on the reconciliation in reconciling broker entry exports with invoices and your ERP.

How do you run the pre-assessment survey on yourself?

The order below follows the phases, with the importer in the auditor's chair.

1. Pull the population. Ask your broker, or each broker, for an entry export covering five years, the 19 CFR 163.4 retention period: every entry, every line, with entry number, entry date, port, HTS number, Chapter 99 headings, SPI, origin, quantity, value, rate, duty and fees. Reconcile the count of entries against ACE so that no filer is missing.
2. Write down the process before testing it. Who assigns HTS numbers and where the reasons are kept; who sets the value and how assists and royalties reach the broker; who maintains the origin file; who checks the broker's work. The pre-assessment survey is about these controls, and a control that exists only in one person's head is the finding CBP's questionnaire is designed to surface.
3. Test the whole export, line by line. Run the comparisons in the table above on every line. A sample is what an auditor can afford; your own data has no such limit, and a full run finds the pattern rather than an instance.
4. Trace a sample end to end. Take a few dozen lines and pull the invoice, packing list, bill of lading, certification of origin and payment record for each. The question is not only whether the line is right but whether you can prove it in a day. 19 U.S.C. 1509(g) attaches penalties to a record you cannot produce.
5. Classify each finding by direction and status. Overpaid or underpaid, and for each entry whether it is unliquidated, liquidated within the last 180 days, or final. The next section says what each combination becomes.
6. Fix the control, then re-test the next month. A follow-up audit checks corrective action; so should you, on the entries filed after the fix.

What does a finding in each area turn into?

The route depends on the direction of the error and the entry's liquidation status, and how long do you have to fix a past entry has the clocks in detail.

Two features of the table matter for an importer expecting a focused assessment. The first is the disclosure timing. 19 CFR 162.74 gives prior-disclosure treatment only to a disclosure made before, or without knowledge of, the commencement of a formal investigation, which 162.74(g) fixes at the date CBP records in writing that it believed a violation was possible. An audit is not an investigation, but an audit can produce a referral, and the importer never sees the date CBP wrote down. A disclosure made from your own review, before any notice, does not depend on that date. Prior disclosure after you find an underpayment covers how to scope one from the export.

The second is the offset. 19 U.S.C. 1509(b) provides that overpayments identified during an audit may offset underpayments on finally liquidated entries in calculating the loss and the penalty under Section 1592, without authorizing a refund beyond what section 1520 allows. In an audit, overpayments you never claimed reduce the exposure; outside one, they are refunds only while their protest window is open. A self-test that finds them while the windows are open is worth more than one that finds them for the auditor.

What should be in order before the letter arrives?

Beyond the entry data, the pre-assessment survey asks about the organisation. The published questionnaire is CBP's; the list below is what the tests above need to exist, in the importer's own files.

• A product master in which each part number carries one HTS number, the reason for it, the date it was set and who set it, with a review step whenever the tariff changes.
• A valuation file that shows how the entered value is built from the invoice, where assists, royalties, commissions and proceeds are captured, and which charges are deducted under which document.
• An origin file with a determination per product and the certifications of origin behind every special program indicator claimed, current for the entry dates.
• A measures calendar: which Section 232, Section 301, IEEPA and AD/CVD measures apply to your products, and from which entry dates, so the duty stack can be reproduced for any line. Why your entry shows the wrong duty stack shows where the stack usually breaks.
• A broker oversight step: a sample of each broker's entries checked against the files above every month, with findings recorded and fed back.
• A record index that lets any entry's full document set be pulled within a day for five years from entry.

CBP's audits page also points auditees to its Informed Compliance Publications, the "What Every Member of the Trade Community Should Know About" series, which describe what reasonable care under 19 U.S.C. 1484 looks like for classification, valuation and origin.

How does a standing audit change the outcome?

An importer whose entries are checked every month, line by line, against the invoice, the packing list and the measures in force on the entry date arrives at the pre-assessment survey with the evidence the survey asks for: a control that runs, findings that were corrected while a post-summary correction was still open, and underpayments that were disclosed from the importer's own review rather than found in testing. TariffSense reads broker entry exports and entry summaries in any layout and flags, per line, where the classification, value, duty stack, origin claim or quantity does not agree with the documents or the measures on the entry date; the post-entry audit page shows what goes in and what comes back. The filings that follow, corrections, protests and disclosures, stay with the importer, its broker and counsel, and a licensed customs broker or trade counsel should confirm any deadline before a filing is made.

What should you do next on your own entries?

Ask your broker for the five-year entry export this week, and pull the invoice, packing list and certification for twenty entries chosen at random. If any of the twenty cannot be assembled in a day, that is your first finding. Then run the column checks in the table above across the whole export, split the findings by direction and liquidation status, and take the underpaid, final entries to counsel before any letter arrives. If a CF-28 has already come in on one of the lines, read CF-28 and CF-29: how to audit yourself before CBP asks first.