Voluntary Self-Disclosures (VSD)

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By: Sean Kline

When is a VSD necessary?

The VSD process is designed for systematic errors rather than the occasional typographical error. For example, if you discover that you failed to file the Electronic Export Information (EEI) for a series of shipments, you should submit a VSD. It is important to know that the filer, whether it is the USPPI or the U.S. authorized agent, must ensure that the EEI is complete, accurate, and timely. It is also vital to keep your records current whether you are the party filing the EEI or providing the information that is filed. If you notice systematic errors in the information filed or information that was not filed for a series of shipments, submit a VSD.

Steps to Take When Submitting a VSD

1) Correct all erroneous records and file new records for any shipments that should have been filed.

2) Prepare documentation detailing each shipment in question with the Internal Transaction Number and value. Some companies find it convenient to submit this information in a spreadsheet format when multiple records are involved. For shipments with errors, you should also show the information that was originally filed and then the corresponding correction.

3) Provide all the information detailed in section 30.74 of the Foreign Trade Regulations which can be found on our website at www.census.gov/trade

4) Mail to the below address found in section 30.74 or fax to, (301) 763-8835. Do not submit your VSD via e-mail.

Chief, International Trade Management Division
U.S. Census Bureau
4600 Silver Hill Road, Room 5K158
Suitland, MD 20746 (if sent by courier) or Washington DC 20233 (if sent by USPS)

The Benefits

Voluntary self-disclosures can be a mitigating factor for civil penalties if Customs and Border Protection (CBP) or the Bureau of Industry and Security (BIS) determine that the USPPI, U.S. authorized agent and/or carrier should be fined or imprisoned for regulatory violations. Submitting a VSD is a great way to come into compliance with the Foreign Trade Regulations and will help you sleep easier. The last thing you want is an unexpected visit from a CBP officer!

If you have any questions or concerns please contact us at 1-800-549-0595 (option 3) or via email.

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2 Responses to Voluntary Self-Disclosures (VSD)

  1. Javier Calderon says:

    Question: if a Company gets fined by the CBP due to erros detected in some EEI via AES, the company has the opportunity to request a mitigation by the CBP. What happen if the company finds out that there are more errors in some additional EEI? Do the company needs to file a VSD to Census or CBP?

    • ITMD Global Reach says:

      @Javier A company should submit a VSD to the Census Bureau if it finds errors which were not already identified by CBP. This VSD can then be used as a mitigating factor for CBP penalties.

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