Prior Disclosures

Prior Disclosures

  • PRIOR DISCLOSURE AND

    Question: My firm is preparing to do a Prior Disclosure for the past five yearsand we noticed that one specific product was classified under an HTS that wasthought to be correct at the time. Upon further review of the facts withour customs broker, we determined that was incorrect due to thepreservatives that are added to […]

  • PRIOR DISCLOSURES

    Question:I was wondering if anyone can share their experience with submitting a prior disclosure for no duty lost, negligent or gross negligent violations. What was the circumstances and do you think that Customs is more lenient for companies that have corrected the issues are disclosing past sins? It seems to me that a company with […]

  • DISCLOSURE OF PRIOR DISCLOSURE

    Question: We received a CF28 for a product in regards to anti dumping. We answered the CF28, filed a prior disclosure for this product. Now, CBP wants to reject our prior disclosure and assess a penalty stating that the CF28 constitutes them notifying us of an investigation. It is not one of the vehicles mentioned […]

  • Prior Disclosures Q&A 1

    I have a question regarding prior disclosures. About a month ago, we received a CF28 requesting a NAFTA certificate for a Canadian import. We didn’t have one, and in working with our broker discovered that for the past several years, they had been mistakenly been making NAFTA claims (also not following our classification database) affecting […]

  • Prior Disclosures Q&A 2

    We are preparing two prior disclosures. One concerns misclassification of goods and the other concerns related party transactions improperly declared. The company trusted their broker and employed no one trained in customs compliance until a few months ago. The violations date to 2001. We have the records in our possession. Do the prior disclosures have […]

  • Prior Disclosures Q&A 3

    QUESTION: I have been asked to pull together a presentation discussing Prior Disclosures of inaccurate hs codes. The presentation will be directed to upper management to explain why Prior Disclosures are important, what is involved in executing them, and what is the risk associated them. We are also concerned how other divisions of our corporation […]

  • Prior Disclosures Q&A 4

    I have been asked to pull together a presentation discussing Prior Disclosures of inaccurate hs codes. The presentation will be directed to upper management to explain why Prior Disclosures are important, what is involved in executing them, and what is the risk associated them. We are also concerned how other divisions of our corporation may […]

  • Prior Disclosures Q&A 5

    Has anyone in the membership had the unfortunate experience of filing a prior exclosure for COO and HS codes listed on NAFTA Certificates for Mexico. If so, would you be willing to share your experience and lessons learned?