Compliance Programs

Importer Self-Assessment Program

Also known as: ISA · ISA Program

The full name of the CBP self-assessment partnership program, also known as ISA — discontinued for new applicants in 2020 and being replaced by Trusted Trader concepts.

The Importer Self-Assessment Program is the official name of the CBP partnership program commonly referred to as ISA. Launched in 2002 under the authority of 19 U.S.C. § 1411 and 19 CFR § 113, the program was designed to allow trusted importers to assume responsibility for monitoring their own customs compliance, freeing CBP audit resources for higher-risk targets.

The program closed to new applicants in 2020 as CBP began developing a unified Trusted Trader framework that integrates supply-chain security (CTPAT) with compliance self-assessment.

Eligibility criteria for ISA membership required:

  • Active CTPAT Tier II or Tier III certification
  • A resident U.S. company importing goods as the importer of record
  • Documented internal controls covering classification, valuation, country of origin, FTAs, antidumping/countervailing duties, and recordkeeping
  • A risk-based testing plan with annual self-testing
  • Signed Memorandum of Understanding with CBP committing to disclosure of identified errors

Why ISA still matters today:

  • Grandfathered members continue receiving benefits
  • The program's structure — documented controls + annual self-testing + prior-disclosure commitment — is the template most large importers still use to demonstrate reasonable care
  • Future Trusted Trader benefits are expected to build on the ISA model
  • ISA-style compliance reviews are still a strong mitigation argument in Section 1592 penalty cases

For new importers seeking the closest equivalent, the path is CTPAT Tier II/III plus documented internal compliance procedures, plus prompt use of prior disclosure when errors are found.

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