Most import transactions fall under Customs and Border Protection (CBP), and since the Customs Modernization Act of 1994, CBP has required that importers show “reasonable care” when making entries. CBP has defined “reasonable care” to include having an expert in compliance review an import company’s overall internal control program or a discrete open question. This expert must be from an outside company and can be an attorney or other expert in the compliance field.
TCS professionals can manage any import compliance activity, which can range from the simplest, single compliance questions to the development of an import or export compliance program. In addition, we can handle the most complex prior disclosure of import violations or voluntary disclosures of export and sanctions violations. Most industry experts will agree that implementation of corrective actions requires counsel that is both sophisticated and nuanced. If necessary, we can advise on the best methods for corrective actions, which may include prior disclosure or voluntary disclosure.
We can collaborate with in-house staff to develop and promulgate the processes and procedures in a carefully drafted manual that is responsive to your legal obligations and attentive to your business priorities. For companies that know what course of action they want to follow, we can be a trusted business advisor who can help you meet your resource constraints and implement developed plans