Client Advisories and Bulletins

Customs and Border Protection Clarifies Expanded Prior Disclosure Benefits Under ISA Program

August 2005

In response to concerns raised by the Global Trade Advisory Group, a Division of Katten Muchin Rosenman LLP, the Assistant Commissioner, Office of Strategic Trade, Daniel Baldwin, and the Strategic Trade Advisor in charge of ISA, Joseph Rees, clarified the intent of the expanded prior disclosure benefits associated with the Importer Self Assessment ("ISA") Program. The Customs and Border Protection ("CBP") officials advised that the expanded prior disclosure benefits are available to ISA participants for all errors in which a CBP official becomes aware that there is an indication of a violation of 19 U.S.C. § 1592 or 1593a over the entire period that an importer is a participant in the program.