‘Mod’ to ‘SOX’ to ‘ISA’

Almost  10 years before the enactment of the Sarbanes- Oxley Act of 2002 (hereinafter SOX), the U.S. Customs Service, now U.S. Customs and Border Protection (CBP), persuaded Congress to enact legislation to mandate many of the same corporate compliance guidelines that are now prevalent under SOX.   That law, the Customs Modernization and Informed Compliance Act (Mod Act), Pub. L. 103-182, became effective Dec. 8, 1993.

This article reviews changes brought by the Mod Act and how the SOX principles mirror the Customs’ compliance program and subsequent development of the Importer Self-Assessment (ISA) program.