How to Audit Your Customs Broker's IEEPA Work

Your customs broker is the operational engine of your IEEPA recovery. They pull the data, file the PSCs, submit the protests, and eventually coordinate your CAPE filings. For most importers, the broker is the only party touching the actual recovery process — which means the quality of their work directly determines how much you recover, how fast, and whether any claims fall through the cracks.

Trusting your broker is reasonable. Verifying their work is smart. An audit doesn’t mean you distrust your broker — it means you’re treating a significant financial recovery with the same rigor you’d apply to any other six- or seven-figure business decision.

This guide walks through a practical audit framework: what to check, how to check it, and what red flags to watch for.

Why Audit?

The IEEPA recovery is a one-time event with irreversible deadlines. Unlike routine import compliance — where errors can be corrected on future entries — mistakes in the IEEPA recovery can permanently reduce your refund. A missed protest deadline can’t be reopened. A PSC filed with incorrect data can delay processing. An entry overlooked in the initial data pull is an entry that doesn’t get recovered.

The stakes are high enough to warrant verification. Here are the specific risks that an audit catches:

Incomplete data pull. The broker may have missed entries — especially entries filed during transitional periods, entries filed under alternate entity names, or entries from a prior broker relationship.

Incorrect categorization. Entries may be categorized as liquidated when they’re still open (or vice versa), leading to the wrong recovery path being applied.

Missed deadlines. The 180-day protest window is entry-specific. If your broker is managing hundreds of entries, some deadline-sensitive entries may not be flagged in time.

Filing errors. PSCs or protests filed with incorrect entry numbers, wrong HTS codes, or missing documentation can be rejected or delayed.

Communication gaps. Your broker may have filed successfully but failed to communicate the status to you — leaving you without visibility into your recovery.

The Audit Framework: Five Checkpoints

Checkpoint 1: Data Completeness

What to check: Did the broker pull ALL IEEPA-affected entries for the entire tariff period (February 4, 2025 through February 24, 2026)?

How to check:

1. Request the raw ES-003 report from your broker. This is the source document from ACE showing all entries under your IOR number.

2. Cross-reference against your internal records:

   • Count the total number of entries in the ES-003 and compare to your internal shipment count for the same period
   • Verify that the date range covers the full IEEPA period
   • Check that the total customs value aligns with your purchase records (within a reasonable tolerance for currency conversions and timing differences)

3. Check for gaps:

   • Are there months with suspiciously low entry counts?
   • Are all product categories represented?
   • If you changed brokers during the period, did the data include entries from the prior broker?

Red flags:

• Entry count is significantly lower than your expected import volume
• The date range starts after February 4, 2025, or ends before February 24, 2026
• Total IEEPA duties are substantially different from what you tracked internally
• Missing entries from specific months or product lines

Fix: If entries are missing, work with your broker to expand the data pull. If you changed brokers, request data from the former broker separately.

Checkpoint 2: Liquidation Status Accuracy

What to check: Is each entry correctly categorized as unliquidated (PSC-eligible) or liquidated (protest-required)?

How to check:

1. Request the liquidation status for every entry from the broker’s ACE data. The ES-003 report includes a liquidation indicator.

2. For a sample of entries (10-20%), independently verify the liquidation status through your broker’s ACE access or by checking the status in ACE directly if you have access.

3. Check the dates. Entries filed more than approximately 314 days ago are likely liquidated. Entries filed less than 280 days ago are likely still open. Entries in the 280-350 day range are the ones most likely to have status discrepancies.

4. Confirm that the broker is monitoring for entries that liquidate during the filing process. An entry that was unliquidated when the assessment was done may have liquidated by the time the PSC is filed — shifting it from the PSC path to the protest path.

Red flags:

• All entries are categorized the same (all unliquidated or all liquidated) — unlikely for a 12-month import history
• No entries flagged as deadline-sensitive (approaching the 180-day protest window close)
• The broker isn’t monitoring for status changes during the filing process

Fix: Request a fresh liquidation status pull if the data is more than 2 weeks old. Entries liquidate continuously, and status can change between assessment and filing.

Checkpoint 3: Filing Completeness and Accuracy

What to check: Were PSCs and protests actually filed for every eligible entry? Were they filed correctly?

How to check:

1. Request confirmation of filing for every entry. The broker should be able to provide:

   • PSC confirmation numbers for unliquidated entries
   • Protest filing receipts for liquidated entries
   • Filing dates for both

2. For protests, verify that each filing includes:

   • The correct entry number and line items
   • Reference to the Supreme Court ruling as the legal basis
   • Reference to the CIT’s March 4 order
   • The correct IEEPA tariff provision (9903.01 or 9903.02)
   • All required supporting documentation

3. Spot-check a sample (5-10 entries) by requesting copies of the actual PSC submissions or protest filings. Compare the filed data against the ES-003 source data to ensure accuracy.

4. Verify that no entries were missed. Compare the total number of entries in the assessment against the total number of entries filed. The numbers should match (minus any entries still pending documentation resolution).

Red flags:

• Unable to provide filing confirmations
• Protests filed without referencing the Supreme Court ruling or CIT order
• Wrong HTS codes on the filing (different from the ES-003 data)
• Entries that appear in the assessment but have no corresponding filing

Fix: Request immediate correction of any filing errors. For missing entries, determine why they weren’t filed and file immediately if within the deadline window.

Checkpoint 4: Deadline Management

What to check: Were all deadline-sensitive entries identified and filed in time?

How to check:

1. Create a deadline calendar. For every liquidated entry, calculate the 180-day protest window close date (180 days from the liquidation date).

2. Compare the protest filing dates against the deadline dates. Every protest should be filed well before — not on or after — the deadline.

3. Check for entries that have already passed the deadline. If any entries liquidated more than 180 days ago and no protest was filed, that’s a permanent loss of administrative recovery rights. The only remaining path is CIT litigation, which is slower and more expensive.

4. Look forward: which entries are approaching their deadlines in the next 30, 60, and 90 days? Is the broker tracking these and prioritizing them?

Red flags:

• Entries where the deadline has passed without a protest filing
• No deadline tracking system in place
• Deadline-sensitive entries not being prioritized over routine filings

Fix: If deadlines have been missed, assess the cost of CIT litigation versus the refund amount at stake. For upcoming deadlines, escalate immediately to ensure timely filing.

Checkpoint 5: Communication and Reporting

What to check: Is the broker providing clear, regular status updates on your recovery?

How to check:

1. Review the broker’s reporting cadence. Are you receiving:

   • Initial assessment summary (what you’re owed, by path)
   • Filing progress updates (what’s been filed, what’s pending)
   • Refund receipt notifications (when money arrives)
   • Deadline alerts (upcoming protest window closures)

2. Evaluate the quality of communication:

   • Are updates proactive (broker reaches out) or reactive (only responds when you ask)?
   • Are status reports clear and actionable?
   • Can you reach the person handling your account when you need to?

3. Compare broker claims against your own records:

   • Does the broker’s total refund estimate match your assessment?
   • Are refund receipts matching what was projected?
   • Are there unexplained discrepancies?

Red flags:

• No proactive communication since initial engagement
• Unable to reach the person handling your account
• Status updates are vague or inconsistent with your records
• Broker claims “everything is fine” without providing documentation

Fix: Set clear expectations for reporting frequency and content. If the broker can’t meet reasonable reporting standards, consider whether a different broker or an advisory partner should coordinate the recovery.

The Audit Scorecard

Score your broker across the five checkpoints:

Score 4.0-5.0: Your broker is performing well. Continue monitoring but no intervention needed.

Score 3.0-3.9: Performance gaps exist. Address specific issues and increase your monitoring frequency.

Score below 3.0: Significant risk to your recovery. Consider supplementing your broker with an advisory partner or transitioning protest filings to a more capable broker.

When to Bring in a Second Opinion

An audit may reveal issues that warrant bringing in additional expertise:

Your claim exceeds $500,000. At this level, even a small error rate translates to meaningful dollars. An independent Impact Assessment provides a second set of eyes on the data and filing strategy.

Your broker scored below 3.0. If the audit reveals significant performance gaps, a supplemental advisory relationship can catch errors and fill gaps without necessarily replacing the broker entirely.

You changed brokers during the IEEPA period. Split-broker situations are inherently more complex and error-prone. An independent coordinator can ensure nothing falls through the cracks between the two brokers.

You have multi-entity complexity. Corporate groups with multiple subsidiaries and IOR numbers benefit from centralized oversight that a single broker may not provide.

You suspect entries were missed. If your internal records suggest higher IEEPA exposure than the broker’s data shows, an independent data pull and reconciliation can identify the gap.

Special Situations That Warrant Extra Scrutiny

Certain circumstances call for a deeper audit than the standard five checkpoints:

High-Value Claims ($1M+)

Claims above $1 million justify a line-by-line review — not just a sample. The dollar amounts at stake mean that even small error rates translate to significant losses. For a $3 million claim, a 2% error rate is $60,000 left on the table.

Multiple Product Categories

If you import across diverse product categories (e.g., both electronics and apparel), your broker may have applied different HTS classifications and IEEPA rates to different products. Verify that the correct rate (20% vs. 34%) was applied to each category. An electronics entry classified at 20% when it should be 34% means the refund claim is understated.

Entries From the First Month of IEEPA (February 2025)

The earliest IEEPA entries were filed during a chaotic implementation period when HTS codes 9903.01 and 9903.02 were brand new. Brokers were learning the classification rules in real time, and errors were more common. These entries also have the tightest protest deadlines — making them both the most error-prone and the most time-sensitive.

Post-Ruling Entries (February 20-24, 2026)

As discussed in the goods-in-transit guide, entries filed between the Supreme Court ruling and CBP’s formal suspension of IEEPA collection may have been assessed duties that shouldn’t have been applied. If your broker filed entries during this period with IEEPA codes, verify whether PSCs have already been filed to correct them.

Entries Involving FTZs or Bonded Warehouses

FTZ withdrawals and bonded warehouse entries involve additional procedural layers that create more opportunities for error. If you operate through either mechanism, add specific audit steps for the FTZ/warehouse entries.

How to Conduct the Audit Without Damaging the Relationship

Auditing your broker doesn’t have to be adversarial. Frame it as collaborative quality assurance:

• Position it as standard practice. “We audit all our major financial processes. IEEPA recovery is a seven-figure item — same standard applies.”
• Request data, not explanations. Ask for filing confirmations, status reports, and documentation rather than questioning their competence.
• Share findings constructively. If you find errors, bring them to the broker as items to resolve rather than failures to criticize.
• Acknowledge good work. If the audit reveals strong performance, tell them. Broker relationships work better when good work is recognized.

The vast majority of customs brokers are competent and well-intentioned. The audit isn’t about catching them doing something wrong — it’s about ensuring a complex, high-stakes process stays on track.

Your Audit Checklist

Start your audit today with these steps:

1. Request the raw ES-003 data from your broker
2. Cross-reference entry counts and duty totals against your internal records
3. Verify liquidation statuses on a sample of entries
4. Request filing confirmations for all PSCs and protests submitted
5. Build a deadline calendar for all liquidated entries
6. Assess communication quality and reporting cadence
7. Score your broker using the framework above

Get your free Impact Assessment →

The bottom line: trust your broker, but verify their work. The IEEPA recovery is too large and too time-sensitive to leave unaudited. The five checkpoints in this guide take a few hours to work through. The peace of mind — or the errors you catch — are worth far more than the time invested.

An independent Impact Assessment serves as both a recovery plan and a broker audit. It pulls your ES-003 data independently, categorizes every entry, identifies deadline risks, and provides a benchmark against which you can evaluate your broker’s work. If your broker is performing well, the assessment confirms it. If there are gaps, the assessment identifies them before they cost you money. Start the process now — protest windows don’t wait, and neither should your quality control.