Follows a Licensed U.S. Customs Broker and Trade Compliance Director after a CBP Focused Assessment Inquiry and CF-28 Request for Information uncover $1.2M in undeclared foreign tooling molds (statutory assists) and an invalid USMCA origin certificate.
On October 26, 2023, Trade Compliance Director and Licensed U.S. Customs Broker Sarah Chen received CBP Form 28 ('Request for Information') initiating a Focused Assessment of GlobalTech Solutions' Malaysian electronics imports. Customs Broker Sarah Chen received CBP Form 28 ('Request for Information') initiating a Focused Assessment of GlobalTech Solutions' Malaysian electronics imports. Customs Broker Sarah Chen received CBP Form 28 ('Request for Information') initiating a Focused Assessment of GlobalTech Solutions' Malaysian electronics imports. Customs Broker, stared at the CBP Form 28, 'Request for Information.' Dated October 26, 2023, the inquiry stemmed from a Focused Assessment initiated on September 15, 2023, targeting GlobalTech's imports of specialized electronic components from Malaysia. The CF-28 specifically demanded detailed cost breakdowns for purchase orders 2023-GT-011 through 2023-GT-015, spanning January to June 2023. A preliminary internal review, prompted by the CBP notice, had already flagged a glaring omission: $1.2 million in foreign tooling molds, provided free of charge to the Malaysian manufacturer, were nowhere to be found on GlobalTech's import declarations. These molds, critical for producing the imported components, represented a significant undeclared 'assist' under U.S. Customs law. Furthermore, an initial scan of vendor agreements revealed potential royalty payments tied to brand usage that might also be dutiable, alongside ambiguous 'service fees' that could be misclassified commissions.