Regulatory Audit Working Closely With CEEs on Compliance Surveys, CBP's Owen Says

NEW YORK -- The Centers of Excellence and Expertise are working closely with the Office of Regulatory Audit as it increasingly uses surveys to explore potential areas of compliance problems, said Todd Owen, CBP executive assistant commissioner, Office of Field Operations, Nov. 9 at the Apparel Importers Trade and Transportation Conference. Through the CEEs, "we look at all the disciplines that touch a company" so "there is that level of communication between the account managers, the import specialists and the auditors as we're going forward with this approach," he said. CBP is using “informed compliance” letters and questionnaires sent to importers as part of a broader shift toward the use of audit surveys in the agency’s compliance verification activities (see 1608090024).

The role and quality of the industry-focused CEEs are continuing to increase, Owen said. "The level of expertise that we are seeing within the Centers really has risen over the past two years," he said. "A lot of the reason for this is because of the engagement with the industry themselves." There are also a number of "internal efficiencies," Owen said. "We no longer have multiple teams addressing things like countervailing duty issues and protests, we've been able to streamline for a lot of that process. We've been able to reduce the protesting time in our Petroleum CEE in Houston," from close to 300 days to 100 days. ACE has been an important part of the improvements, though "ACE still needs additional functionality in certain areas that will get us even further," he said.

CBP is also still working to increase the benefits available as part of Customs-Trade Partnership Against Terrorism members through the Trusted Trader program (see 1604290023), now operated as a pilot, Owen said. The Trusted Trader concept includes a "much less intrusive review of your internal controls," he said. National account managers, rather than auditors, handle the review, he said. "What started as a security focused program has now expanded to include trade compliance and the reason for that" is to allow for U.S. C-TPAT importers and exporters to receive the benefits provided for under mutual recognition agreements, Owen said.