Customs Self Assessment Compliance Program CSACP

1
Customs Self Assessment Compliance Program
(CSACP)

• An Overview Presentation
• to CTACCDecember 10, 2002.

2
Customs Self Assessment Compliance Program

• What is it?
• Builds on CSA
• Proposed compliance partnership pilot between the
  importer and CCRA
• ISO standards-approach to customs compliance
• Greater importer responsibility for compliance
  audits

3
Customs Self Assessment Compliance Program

• Why it makes sense?
• Assurances that compliance efforts are recognized
• Opportunity to share best practices with CCRA
• Limit exposure to AMPS to provide greater
  certainty for the importer

4
Customs Self Assessment Compliance Program

• What will it do?
• Importers
• Build a system/process of continuous compliance
  improvement
• Requires importers to commit resources to
  compliance activities on a daily basis
• Provide certainty that compliance efforts will be
  recognized by CCRA

5
Customs Self Assessment Compliance Program

• What will it do?
• CCRA
• Free resources to devote to high-risk less
  compliant importers
• Provide certainty that importers have a
  demonstrated commitment from senior management
  to place customs compliance as a key business
  priority
• Maximize the economies of scale for CCRA
  investment in CSA by growing the critical mass
  of importers

6
Customs Self Assessment Compliance Program

• Why should the importing community support this
  proposal?
• Industry and CCRA continue moving towards a more
  modern approach to compliance programs
• Encourages compliance and a risk based focus to
  import management
• Eliminates a one size fits all approach to
  penalties

7
Customs Self Assessment Compliance Program

• Relationship to CSA?
• CSA is risk-managed approach to release and
  accounting
• CSACP is a risk-managed approach to compliance
• Encourages the expansion of the partnership
  between CCRA and the importer
• Increases the reliance on the importers records
  and processes
• Improved information sharing and transparency

8
Customs Self Assessment Compliance Program

• How do SMEs fit in to the program?
• All importers can apply for CSA
• CSACP provides more incentive for the investment
  if AMPS are limited
• A similar program maybe considered for importers
  willing to make the commitments to increased
  compliance

9
Customs Self Assessment Compliance Program

• What is the relationship to AMPS?
• Assists CCRA in modifying importer behaviour to
  make AMPS corrective and not punitive
• Serves as a preventative mechanism that corrects
  errors before the application of AMPS
• Confirms compliance as a standard to the
  day-to-day operations
• Reward for exceptional compliance efforts

10
Customs Self Assessment Compliance Program

• CSACP Process Proposal
• CSA participant
• Partners in Protection
• CSACP Memorandum of Understanding
• Maintain a system of business processes that
  demonstrate compliance
• Establish, document and implement internal
  controls
• Perform periodic testing based on risk
• Maintain results for five years
• Make appropriate adjustments to controls
• Make appropriate disclosures
• Annual written notification
• Questionnaire

11
Customs Self Assessment Compliance Program

• Overview of Questionnaire
• Does your company maintain an internal customs
  office dedicated to maintaining and updating
  regulations, laws and customs operations?

12
Customs Self Assessment Compliance Program

• If not in house, do you have a contract with a
  customs brokerage house or consulting service to
  provide this advisory assistance?

13
Customs Self Assessment Compliance Program

• Do you maintain an audit trail from
  financial/business records and payments to
  customs entry records?

14
Customs Self Assessment Compliance Program

• Are your customs internal control processes
  consistent with the guidance provided by external
  bodies such as The Criteria of Control Board of
  the Canadian Institute of Chartered Accountants
• Control environment
• Risk assessment
• Control activities
• Information and communication
• Monitoring

15
Customs Self Assessment Compliance Program

• Are the customs internal control procedures
  implemented in the company divisions that are
  responsible for the importation of merchandise?

16
Customs Self Assessment Compliance Program

• Have you identified customs risks related to your
  companys import operations?
• Does your company have procedures to monitor and
  correct compliance deficiencies?

17
Customs Self Assessment Compliance Program

• Has your organization set up a plan to perform
  periodic testing ( at least an annual review of
  significant risk areas) in the companys
  divisions that have an effect of imported
  merchandise?

18
Customs Self Assessment Compliance Program

• Do you have departmental meetings to discuss and
  coordinate changes to your customs internal
  control system when tests or other information
  show a need for compliance improvement?
• Do you have an assigned officer who will initiate
  a disclosure to CCRA when your system tests show
  material errors?

19
Customs Self Assessment Compliance Program

• Are systems tests and customs internal control
  processes documented and retained by your
  company?b
• Is your internal control documentation, including
  tests and test results, maintained for 5 years
  and available for CCRA review?

20
Customs Self Assessment Compliance Program

• What is the process for moving forward?
• Establish a CTACC committee to work on refining
  the concept
• Implement concept on pilot basis in first half of
  2003