Steps
Review Data Needed for Audit
- ITRAC (CBP entry information)
CBP provides a disc on a quarterly basis
- Import Data also used to compare
Data taken from BW and ACH Reports
Revise Import Manual in light of new system procedures, corporate, or personnel changes
ISA Testing Data
- Entry Information
- Classification Review
- Quantity Review
- Reported & Unreported Value Review
- SPI Verification
- Recordkeeping Review
- Related Party Indicator
- MID
- Look for Anomalies in data
Entry Information
- Extracted from ITRAC data
Select at least 2-3% of import entries as samples for testing of the criteria on previous page
- Once samples are selected, add to template and assign a sample number
Classification Review
- Binding Ruling
If yes, record ruling #.
If no, review classification to confirm that it is correct.
- Verify to Import Master Sheet
- Invoice #
- Vendor
- Classification correct as entered
- Recommended Classification if incorrect
Quantity Review
Quantity Verification in GTS for Purchase Orders
Quantity Verification in GTS for Sales Orders (Direct Delivery)
Reported Value
Value/Payment Verification for material received
SPI Verification
- Indicate SPI flag (A, CA, MX…etc.)
- Sample should include at least two of every SPI / country combination
- Confirm that records include appropriate certification of origin from vendor
- Investigate discrepancies
- Correct as needed, making notations on spreadsheet
Unreported Value Review
- Select sample (10) from each GL report
- Foreign vendors only
- RCS (both PO# and SO#/coded)
- Data from (General Ledger): vendor name, vendor number, vendor country, vendor address, invoice #, PO# (or SO#/coding), amount paid, quantity received
- Data from ITRAC: entry number, invoice #, quantity, value
- Review GL reports for anomalies
- Confirm amount paid and quantity received agree with invoice and entry information
Record keeping Review
Mandatory Documents
- CF 7501
- CF 3461
- BOL
- Delivery Order
- Import Master Sheet
- Commercial or Pro-forma Invoice
- USDA Stamp
- TSCA Stamp
- Insurance & freight support
Optional
- Packing list
- Certificate of origin (mandatory for GSP and FTA entries only)
- Certificate of analysis
- Proof of Payment
Completed spreadsheet and annual report sent to CBP by email
Florence Constant-Gibson
Chief, Trade Compliance Branch
Office of Field Operations
DHS/U.S. Customs & Border Protection
1300 Pennsylvania Ave., NW
Washington, DC 20229-1015
Phone: 202-344-1536















