The year is 2022, and companies are turning over a new leaf,
making a concerted effort to become compliant with U.S. Customs
laws and practices. Seemingly, there are no downsides to conducting
a comprehensive Customs compliance review and submitting a Prior
Disclosure under 19 U.S.C. § 1592(c)(4) and 19 C.F.R. §
162.74.
And now, the proverbial "BUT."
"BUT," be prepared to complete that comprehensive
internal review, optional statistical sample, loss of revenue
quantification, applicable tender, and finely crafted Prior
Disclosure narrative in 60, or 90, or 120 days.
Just in time for the new year, U.S. Customs and Border
Protection has adjusted their policies regarding Prior Disclosure
extension requests. The only problem is that most ports are
interpreting the policy vastly differently, and it's a
crapshoot to determine whether the extension will be granted or
just how many extensions you will get.
