 Customs Audit Activity Increasing but Companies Can Take Steps to Mitigate Impact |
Source |
American Shipper |
Post Date |
06/12/2026 |
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Customs audit-related activity and penalties are on the rise, but companies can take a number of steps before and during audits to mitigate their potential impact.
U.S. Customs and Border Protection conducts audits and other professional services throughout the U.S. Audits generally have targeted objectives, involve data analysis and risk assessment procedures to determine scope, and are compliance-driven. Deping on the objective the audit may or may not include an assessment of the importer? internal controls over customs compliance. Audits also include focused assessments, which are comprehensive audits that use a risk-based approach to determine if the importer represents an accep risk to CBP.
CBP also conducts risk analysis and survey assessments, which are not performed as audits but require assistance consistent with auditors?ss and expertise. RASAs allow CBP to obtain information about a company? import activities related to a specific trade area or issue. While they can be an opportunity to avoid a more intensive review, they can also result in full-blown audits or other enforcement actions if they are not taken seriously.
CBP recently reported that the number of audits it completed annually increased from 417 in fiscal year 2024 to 465 in FY 2025. Other audit-related activity also increased during that time, including the following.
- revenue collected from importer audits: from $117.7 million to $235.5 million (+100.1 percent)
- number of trade penalties issued: from 2,204 to 2,432 (+10.3 percent)
- number of liquidated damages: from 22,399 to 53,052 (+136.8 percent)
- revenue collected from trade-related penalties and liquidated damages: from $26.3 million to $46.0 million (+74.9 percent)
These statistics highlight CBP? increasing scrutiny of import compliance and the consequent need for importers to take proactive steps to maximize compliance while preparing for potential audits.
Daryl Moore, Customs Audits and Partnership Programs Leader for Sandler, Travis & Rosenberg, states that knowing your import data and acteristics and conducting regular internal reviews and risk assessments are important foundational measures because they can help companies identify problem areas and determine how to respond before the government gets involved. If these processes do reveal actual or potential violations the importer has the opportunity to submit a prior disclosure, which can help reduce any penalties that may ultimately be assessed.
There are also things importers can do during an audit to make the process go more smoothly, Moore states. These include taking the initial contact seriously and engaging experts early to determine what CBP is after, recomm how best to respond, and represent the importer? interests in dealings with the agency. Perhaps most importantly, Moore adds, importers should have qualified service providers review any information before it is submitted to CBP. This step alone can significantly reduce the time and expense of an audit.
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