A Quick Response Audit (QRA) is a targeted, single-issue audit conducted by CBP Regulatory Audit and Agency Advisory Services under the authority of 19 U.S.C. § 1509. Unlike a comprehensive Focused Assessment, a QRA is narrowly scoped to one specific compliance question and is typically completed within 60–120 days.
Common QRA triggers:
- A specific HTS classification appears questionable across multiple entries
- The importer's valuation methodology raises concerns (e.g., aggressive first sale declarations, undeclared assists or royalties)
- Use of an FTA or Chapter 98 provision needs verification
- Section 301, Section 232, or AD/CVD evasion concerns
- Recordkeeping compliance under 19 CFR Part 163
- Country of origin claims (particularly USMCA certifications and UFLPA due diligence)
QRA scope:
- Typically covers 1–2 years of entries
- Focused on a single issue, product line, or compliance area
- May involve targeted sampling rather than full statistical sampling
- Often initiated in response to a specific intelligence trigger (industry pattern, trade complaint, prior disclosure, internal CBP referral)
QRA process:
- CBP issues a notification letter identifying the audit scope and document request
- Initial conference with the importer's compliance and counsel teams
- Document production and on-site or virtual review
- Closing conference and draft report
- Final audit report — either "Acceptable" or referring to penalty action / duty recovery
Outcomes:
- If the QRA finds no issues, the audit closes "Acceptable"
- If issues are found, CBP can demand back duties, refer to Fines, Penalties, and Forfeitures (FP&F) for Section 1592 action, or expand the audit into a Focused Assessment
Strategic response: A QRA is often best handled by treating the issue as if a Section 1592 action were already underway — documenting reasonable care, considering whether a prior disclosure on related entries makes sense, and preserving all relevant records. QRA findings often become the foundation for later penalty cases.