Verification, audits, and customs investigations
What the exam tests
This domain tests how customs verifies origin and how an importer should respond. You must know documentary checks, questionnaires, site visits, supplier verification, burden of proof, time limits, voluntary disclosure, and penalty exposure.
Verification process
Customs may request the certificate, invoice, BOM, cost data, supplier declarations, production records, and transport documents. It may contact the exporter or supplier directly under the agreement. The importer generally bears the burden of substantiating the claim. Findings can lead to denial, retroactive duty, interest, and penalties; voluntary disclosure before discovery can mitigate penalties. Keep records for the required retention period and prepare a verification file before the first request.
Worked example
Customs selects an FTA claim for a machinery shipment. The importer supplies a valid certificate but no BOM or supplier declarations. Customs verifies the foreign supplier and finds that a key component is non-originating and exceeds de minimis. The claim is denied and duty is assessed retroactively. A voluntary disclosure after the audit begins has less mitigating value than one made earlier.
Traps
Assuming a certificate ends the inquiry; missing customs deadlines; providing inconsistent BOM and cost data; failing to prepare suppliers for verification; ignoring record-retention rules.