Reasonable Care

Reasonable Care


    QUESTION: I have a colleague who has been asking about worst-case scenarios and whether or not I have controls in place to prevent them from occurring. I realize risk has a lot to do with the robustness of the compliance program, but some of these scenarios could happen to even the most robust program. How […]


    QUESTION: We import a product from country A. If the product was imported from country B there would be ADD or CVD duties in play.   I would like to conduct an internal audit to validate that the product is actually from country A and not country B. I don’t suspect any wrongdoing. I simply […]


    Question:   Question for the membership – is there a regulation or other Customs document that can be pointed to with regards to Customs Informed Compliance Notices – how they are to be handled, time limit for responding, extensions available, etc.

  • Reasonable Care Q&A 1

    At what level of an organization does the responsibility/culpability for reasonable care or lack thereof reside in an audit situation? Manager? Board of Directors? To what degree at each level? Does it change if one or more of the levels is a licensed broker?

  • Reasonable Care Q&A 2

    Will you pls ask the group what the average salary for a person with 9 yrs experience as an Ops Mgr/Entry Specialist in a Customs Brokerage firm and 2 yrs experience as an Assistant Import Mgr with a major retailer/importer handling the following duties, but not having a degree or broker’s license, would be: * […]

  • Reasonable Care Q&A 3

    During a recent audit, I found that our broker often incorrectly claimed unrelated parties on many of our import entries. I have put corrective actions in place to catch these types of errors going forward, but in the event of an audit what could CBP say about this?

  • Reasonable Care Q&A 4

    QUESTION ON SUPPLIER ACCURACY: We are a distributor and request HTS number from suppliers which we randomly validate. I have a supplier that gave a 3824 catagory when asked for HTS/ECCN information and gave 2903 catagory when asked for NAFTA information. How are others handling gathering & verifying that the information provided is accurate.

  • Reasonable Care Q&A 5

    We are a multi-national company, and want to determine how to address compliance globally. The first idea is to do a risk assessment, and get information from each area about the countries they import from or export to, the frequency of those transactions, the dollar amount of those transactions on an annual basis, etc. I […]