• Deanna Clark-Esposito

How Can an Importer Build an Effective Internal Compliance Program?



Whether it’s spelled out on a single page or makes up an entire manual, a basic compliance program is one where there are internal controls and procedures that implement compliance measures for those laws and regulations an entity must abide by in its day-to-day operation of the business.


Having an effective program is strengthened when there is a culture of accountability in which individuals understand the concept of compliance and their part within the compliance chain.


To be an effective compliance program internal controls and procedures need to be actively implemented and revised with key personnel updated on changes in practices.

Not only is US Customs interested in seeing an importer’s compliance procedures when being audited or upon application to a voluntary program such as C-TPAT (Customs Trade Partnership Against Terrorism) or ISA (Importer Self Assessment), but it can also play a role in the mitigation of penalties when incidents occur that give rise to such assessments.


Be sure to put together a compliance program that fits your organization, implement it, and update it regularly throughout the year.


Top compliance risks should be identified with resources allocated to address them accordingly. A common area of risk for an importer is that within its supply chain. Mitigation of risk can occur by an importer actually knowing where its cargo is coming from, who the actual supplier is and where the imported merchandise is going to.


It may sound simple, but these transactions are not always as clear cut as they would seem at face value.


Some factors that can make a compliance program appear to be a failure include


· A failure to tailor and update the program

· Insufficient training and follow through of personnel

· Inconsistent enforcement of internal procedures, and

· An inadequate compliance culture


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