Voluntary disclosure under 19 USC § 1592 provides penalty mitigation for importers who self-disclose violations to CBP before discovery. Reduces penalty multiplier (typically from 4x to 1x). Filing structure: written disclosure, identification of violations, period covered, supporting documentation, voluntary tender of duty owed.
This guide covers Voluntary Disclosure Process. Importer education spans setup, ongoing operations, and compliance program design.
Practical implementation depends on company size, sector, and operational structure.
When voluntary disclosure applies
Self-identified violations before CBP discovery. Common after self-audit identifying systemic issues.
Filing structure
Written disclosure to CBP regulatory audit. Detailed identification of violations, period covered, calculations, supporting documentation.
Voluntary tender component
Calculate duty owed and pay it concurrent with disclosure. Reduces penalty exposure further.
Penalty mitigation
Penalty multiplier typically reduced from 4x to 1x. Demonstrates good-faith compliance posture.
Frequently asked questions
When does this apply?
Most relevant for SMB importers facing the named situation or considering the named strategy.
What documentation is needed?
Standard CBP forms plus topic-specific records.
What is the timeline?
Initial assessment 2-4 weeks; complex implementation 8-16 weeks.
What does this cost?
Project work typically $5,000-$25,000. Ongoing retainer for active operations.
How do I begin?
Book a 15-minute scoping call. We confirm fit before any engagement.
Get started
Engage on importer setup or compliance program design.