Tag: Prior Disclosure


  • CBP penalty mitigation strategies. Section 1592, voluntary tender, prior disclosure, penalty reduction factors.

  • Section 1592 customs penalty structure. Three culpability levels – negligence, gross negligence, fraud. Penalty calculation and exposure.

  • Section 1593a customs fraud penalties. Aiding fraud, broker liability, criminal exposure, mitigation.

  • Importer self-audit methodology. Sample selection, scope, gap identification, remediation through PSC and prior disclosure.

  • Pre-acquisition customs compliance review for buyers. Compliance posture, exposure quantification, disclosure schedule preparation.

  • Voluntary tender vs prior disclosure for compliance gap remediation. Different pathways, different penalty implications.

  • Voluntary disclosure process for customs violations. Filing structure, penalty mitigation, scope decisions.

  • Prior disclosure benefits under 19 USC § 1592. Penalty cap, filing requirements, scope.