Data Intensive Analysis to Improve Compliance  

In today’s environment of shared responsibility: informed compliance by CBP and reasonable care standards by Trade, K&A offers a methodology to manage and control the data elements associated with import and drawback compliance. This approach complements the way CBP has changed its audit approach from a traditional data intensive exercise to Focused Assessments.


The current CBP regulatory audit approach in “Focused Assessments” (FAs) is risk based reviewing internal controls (systems, processes, and procedures) to predict future compliance. The FAs extend well beyond the common import documents into the areas of accounting, tax, inventory, manufacturing and IT systems used to store and process data furnished to CBP. CBP expects companies to treat their customs responsibilities, including self assessments, with the same level of care with which they treat their tax responsibilities. Anything less may not be viewed as meeting the reasonable care standards and may result in significant penalties.

Today’s trade environment necessitates the need to address the totality of the import process and not just individual import transactions. Data integrity (i.e., value, classification, and quantity) is critical to establish before processing drawback claims. Any data inconsistencies in value, classification, or quantity can affect the duty amounts due CBP and the duties eligible for drawback. K&A services differ from those of many drawback service providers because K&A integrates software technology into the review process and offers, by means of electronic integrated data files, a bird’s eye view of a company’s import operations.

K&A has developed an electronic approach to manage the data flow. Our systems approach can track all drawback eligible import transactions, link these entry transactions to the importer’s inventory and financial records and evaluate an importer/drawback claimant’s database for inconsistencies in the areas of value, classification, or quantity - by part level, vendor or time period – prior to claiming drawback. We recognize that import data management is critical to the drawback process. More importantly, the K&A emphasis is on data analysis and not just on data collection. This is the key to managing and implementing compliant import and drawback programs.

The K&A import, valuation, and drawback services are tailored to the client’s business practices, implemented and managed by a licensed customs broker with in-depth customs experience.

A Systems Approach to Duty Drawback™