Customs Audits & CBP Audit Defense

Customs audit attorney & CBP audit defense lawyer. Focused Assessments, Section 1592 penalties, prior disclosure. California. (818) 514-7680.

International Trade & Customs Law Services

Comprehensive customs and tariff defense for California importers at the Port of Los Angeles, Port of Long Beach, and all U.S. ports of entry. Services include CBP audit defense, tariff classification, customs valuation, Section 301/232/IEEPA tariff strategy, UFLPA forced labor compliance, duty drawback recovery, and Court of International Trade litigation.

Current Tariff Landscape

With effective tariff rates at historic highs, California businesses need experienced trade counsel. We handle Section 301 China tariffs, Section 232 steel/aluminum tariffs, IEEPA tariff refund claims, and reciprocal tariff compliance.

Free consultation for importers: (818) 514-7680.

Filed Court of International Trade Actions

Trembach Law Firm is not only admitted to the U.S. Court of International Trade — it files its own IEEPA refund complaints there under 28 U.S.C. § 1581(i), with new complaints filed as importers sign. CBP deployed CAPE Phase 3 — which covers finally liquidated entries for plaintiffs holding a court reliquidation order — on October 6, 2026. As of October 28, 2026 the firm is counsel in 35 actions at the Court of International Trade, docket numbers 1:26-cv-04095, 1:26-cv-04154, 1:26-cv-04156, 1:26-cv-04164, 1:26-cv-04185, 1:26-cv-04248, 1:26-cv-04271, 1:26-cv-04277, 1:26-cv-04300, 1:26-cv-04327, 1:26-cv-04328, 1:26-cv-04335, 1:26-cv-04342, 26-04390, 26-04392, 26-04393, 26-04394, 26-04395, 26-04396, 26-04418, 26-04421, 26-04488, 26-04556, 26-04559, 26-04563, 26-04568, 26-04569, 26-04616, 26-04617, 26-04618, 26-04643, 26-04668, 26-04745, 26-04766, 26-04797 (list and verification: Court of International Trade filings). Anatolii Trembach is admitted to practice before the Court of International Trade and is licensed in California, State Bar #349304, verifiable at apps.calbar.ca.gov.

This matters for IEEPA refunds specifically. The Court of International Trade has ordered CBP to reliquidate and refund on plaintiffs’ entries, and CBP’s CAPE Phase 3 for finally liquidated entries is likewise available only to importers who are plaintiffs at the Court. An importer who never filed has no confirmed, self-executing mechanism. Choosing counsel who has actually filed at that court, rather than counsel who only describes the process, is therefore a practical question and not a marketing one.

Jurisdiction over these actions rests on 28 U.S.C. § 1581, and the window to sue runs under 28 U.S.C. § 2636(i). No particular outcome is promised or guaranteed.

Fees, Costs and Case Results

Representation in these matters is offered on a contingency basis covering attorney fees only: there is no attorney fee unless we recover, and clients remain responsible for case costs, such as court filing and service fees. The specific terms that apply to a matter are set out in the written fee agreement for that matter.

Where this site refers to a verdict, settlement or court order, that result was dependent on the facts of that case, and results will differ if based on different facts. Past results do not predict or guarantee the outcome of any other matter, and no particular outcome is promised or guaranteed.

Frequently Asked Questions

What is a CBP Focused Assessment and how should I prepare?
A CBP Focused Assessment is a comprehensive audit of your import compliance systems conducted by CBP's Regulatory Audit Division, examining classification, valuation, country of origin, recordkeeping, and internal controls. Preparation should begin immediately upon notification by engaging an experienced customs audit attorney, conducting internal customs compliance investigations and mock audits, organizing documentation, and developing response strategies. Our focused assessment customs audit team guides California importers through every phase using our multi-year customs audit strategy approach.
What is the difference between a Focused Assessment and Quick Response Audit?
Focused Assessments are comprehensive, multi-month audits examining all aspects of import compliance with potential for significant customs duty underpayment investigation. Quick Response Audits are narrower, expedited reviews targeting specific issues identified through port examinations. Both can result in substantial duty assessments and Section 1592 penalties if compliance deficiencies are found. Our CBP audit defense lawyers handle both types of CBP audits with structured defense strategies.
How can prior disclosure reduce customs audit penalties?
Prior disclosure under 19 CFR 162.74 allows importers to voluntarily report violations before CBP discovers them, limiting penalties to interest on unpaid duties. As an experienced prior disclosure customs attorney, we evaluate prior disclosure cost-benefit analysis, determine eligibility for prior disclosure and mitigation, prepare compliant submissions, and file petitions for relief from customs penalties. Timing is critical - disclosure must occur before CBP initiates an investigation.
What is the reasonable care standard for customs compliance?
The reasonable care standard under 19 USC 1484 requires importers to exercise informed compliance by making reasonable inquiry and using appropriate resources to ensure accurate entry declarations. CBP evaluates whether you have documented compliance procedures, conduct internal audits, seek professional guidance for complex issues, and maintain adequate recordkeeping and customs books and records. Our customs audit attorneys help establish reasonable care documentation.
How do I respond to a CBP Form 28 (CF-28) Request for Information?
A CF-28 is a Request for Information from CBP seeking clarification on your import entries. Our CBP Form 28 response assistance includes analyzing the request scope, gathering supporting documentation, preparing strategic written responses, and preventing escalation to enforcement action. Proper CF-28 response can avoid CF-29 notices and prevent targeted enforcement audit customs lawyer involvement.
What should I do if I receive a CBP Form 29 (CF-29) Notice of Action?
A CF-29 indicates CBP has made a rate advance or other determination affecting your entries. Our CBP Form 29 notice of action defense team immediately reviews the notice, evaluates protest options under 19 USC 1514, gathers evidence to challenge the determination, and protects your rights within required timeframes. This is a critical stage requiring experienced customs audit attorney representation.
What are Section 1592 penalties and how can they be defended?
Section 1592 (19 USC 1592) penalties apply to material false statements or omissions in import transactions. Penalties range from loss of revenue (negligence) to 4x domestic value (fraud). Our Section 1592 penalty defense lawyer services include challenging CBP's culpability findings, demonstrating reasonable care, filing petitions for relief from customs penalties, negotiating settlement amounts, and pursuing administrative appeals through our civil and criminal customs investigations defense practice.
When should I hire a customs audit attorney?
You should engage a customs audit attorney immediately upon receiving any CBP audit notification, CF-28, or CF-29. Early involvement enables customs audit preparation and mock audits, prior disclosure evaluation, strategic response development, and protection against escalation. Our urgent CBP audit response hotline provides emergency response to CBP holds and exams. High-risk importer customs defense teams should be engaged proactively for continuous import monitoring and testing.
How much does customs audit defense cost?
Customs audit defense costs vary based on audit type, complexity, entry volume, and issues involved. Our boutique U.S. customs audit law firm offers white glove CBP audit defense service with transparent fee structures. We provide initial consultations to assess exposure and develop cost-effective defense strategies. The investment in professional representation typically saves significant money compared to uncontested penalties and duty assessments.
What is the CBP audit timeline from notification to resolution?
CBP Focused Assessments typically span 12-24 months, including Pre-Assessment Survey, document production, transaction testing, and final report phases. Quick Response Audits are completed in 2-6 months. Our multi-year customs audit strategy accounts for extended timelines while our CBP regulatory audit management keeps cases on track. Post-audit customs compliance remediation and repeat customs audit prevention programs follow resolution.
What happens during a Homeland Security Investigations (HSI) customs investigation?
HSI conducts criminal investigations into customs fraud, smuggling, and trade violations. Our homeland security investigations customs counsel and ICE and CBP joint investigation defense team handles special agent customs fraud interviews, proffers and statements to customs agents, and whistleblower customs fraud allegations counsel. We provide special agent interview preparation lawyer services to protect your rights during these serious investigations.
Can I handle a CBP audit without an attorney?
While possible, handling a CBP audit without experienced U.S. customs audit representation significantly increases risk. Importers often inadvertently make admissions, miss deadlines, or fail to assert defenses. Our strategic customs audit defense advisors and customs audit playbook for importers methodology prevents common mistakes. For ultra-complex multinational customs audits, professional representation is essential.

Contact Trembach Law Firm

Trembach Law Firm, APC

27001 Agoura Road, Suite 350, Calabasas, CA 91301

Phone: (818) 514-7680

Schedule a Free Consultation | View All Practice Areas | Attorney Profile