The business realities of global trade are constantly changing. Not only do importers and filers have to adapt to meet these realities, CBP does as well. The increasing complexity of global trade means more joint ventures, more complex import transactions, and simply many other situations that were not envisioned during the drafting of many import laws. These days many import transactions contain indeterminable information – that is at the time of import. More and more transactions involve adjustments to the price paid or payable that are not known until months after the import transaction occurs. Filers and ports of entry established processes and procedures for reporting these adjustments such as protests and prior disclosures. These local versions of “reconciliation” were problematic because the procedures varied from port to port, often had no legal basis, and lacked adequate financial controls.
