A Focused Assessment (FA) is the principal comprehensive audit conducted by CBP Regulatory Audit and Agency Advisory Services (RAAAS, formerly Regulatory Audit) under the authority of 19 U.S.C. § 1509. An FA is designed to evaluate an importer's overall customs compliance program — not a single shipment or issue — and typically covers multiple years of import activity.
Two phases:
-
Phase I — Pre-Assessment Survey (PAS)
-
Phase II — Assessment Compliance Testing (ACT)
- Only triggered if Phase I is Unacceptable
- CBP performs statistically valid sampling to quantify the importer's compliance rate
- Identifies systemic errors and required corrective actions
- Can result in Section 1592 penalty referrals and significant duty assessments
Audit scope typically covers:
- Classification (HTS)
- Valuation (transaction value, first sale, assists, royalties)
- Country of origin and origin marking
- Antidumping/countervailing duties (ADD/CVD)
- Section 301 and Section 232 compliance
- Free trade agreements
- Recordkeeping under 19 CFR Part 163
- Reasonable care documentation
Duration: A Focused Assessment typically takes 6–18 months from kickoff to final report. The audit covers a "look-back period" of typically 1–3 years from the audit start.
Selection criteria: CBP selects FA targets based on risk — high-volume importers, products with active trade remedies, sectors with recent enforcement priorities (UFLPA, AD/CVD evasion), and importers with prior compliance issues.
Avoiding an FA: Active CTPAT Tier II/III with documented internal controls, prior ISA membership (grandfathered), and a strong prior disclosure track record significantly reduce FA selection risk. A Quick Response Audit is the targeted single-issue alternative for narrower CBP concerns.