I will conduct an on-site review of current import procedures and compliance policies. This import readiness assessment (audit) will be the first step towards achieving the goal of helping se’lux establish, implement and maintain your own Import Management System (IMS). An IMS is a customized, written accumulation of your compliance with all U.S. Import Administration Regulations. During the assessment I will be reviewing sample documentation and cover areas of due diligence such as: |
- Import procedures- meet with each department involved in the import process from purchasing, production, accounting, and receiving to understand the flow of the import process and review general import compliance procedures.
- Understand if there are or should be any US goods returned, TIB’s (temporary importation bonds, duty drawback or FTZ’s (foreign trade zones) in place.
- Look at the use of your surety bond and power of attorneys with your customs brokers.
- Review International documentation- Proformas, commercial invoices, packing lists, bills of lading, certificates of origin, entry summaries.
- Samples, valuation & transfer pricing – what constitutes a sample, are you using the transaction value method for valuation, how do you determine transfer price.
- HTS- Harmonized Tariff Schedule – do you have a list of each product, when was it last updated, and is the HTS accurate.
- Insurance- What coverage do you have and at what point in the transaction
- Marking requirements – is origin marking complete/accurate
- Review your current international terms and conditions write-up
- Purchase Order - Are you covering all areas of exposure
- NAFTA Certificates – are you obtaining them if your goods qualify, do you know how to use them for proof on your exports.
- Incoterms usage – what terms are you using and why
- Security requirements – From physical security to internal security procedures.
- Record keeping- Are you keeping all required A1A documents, if so where and for how long.
- Warehouse and receiving procedures – what are they and when are you required to notify customs of variations from documentation.
- C-TPAT, FAST, CSI, 24 hour rule, ISA, what are these customs programs and how do they effect you.
I will then deliver a report of findings with suggestions for improvement, highlighting critical areas or violations that need immediate attention, other areas of non-compliance and best practices. This assessment will allow you to see a current snapshot of where your companies import strengths and weaknesses are. It will allow you to prioritize and then decide to either make corrections on your own, or if necessary, work through Allocca Enterprises or another organization to bring your company into full compliance
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