CBP once existed to help you get your goods through the door.

In 2026, they have a different mission.

CBP has rebuilt itself around enforcement — and it’s using AI on top of the ACE database to pursue that new mission.

That means CBP is no longer pulling a small sample of your entries in hopes of catching something. CBP looks at everything now. It sees patterns across importers, brokers, and time. The errors your team used to get away with are now being found.

So what should you do about it?

Start with this:

We’ve built a platform and process that empower you to audit your entries exactly the way CBP now audits them.

Follow this 7-step process, and you can find your errors inside the 10-day window where you can still fix them. Stick with the status quo — and watch the CF-28s pile up.

Step 1: Start From the Source

Pull the commercial invoice, the packing list, and the bill of lading. Those documents are your ground truth.

The 7501 is what your broker decided to file. Audit the entry against the broker’s own output, and you’re checking their math against their math. Start from the documents that came before the filing, or you’re not auditing anything.

How 3rdwave does it: Our intelligent document processing reads your commercial invoices and trade documents as they arrive, and files them in a single repository. Every audit starts from those source documents, never from the broker’s entry. That’s the line between validating a filing and rubber-stamping it.

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Step 2: Rebuild the Entry From Scratch

Take the source documents and your product master and reconstruct what the entry should say — independently.

Don’t anchor on what was filed. Produce your own answer first, then compare. Doing this by hand for one entry is tedious, but doing it for every entry is the part no team can keep up with.

How 3rdwave does it: This is the core of what we built. The 3rdwave entry-writing engine reconstructs a full 3461 and 7501 for every entry, straight from your documents and product profiles. It gives you an independent, calculated entry to hold up against the broker’s. It’s a second set of books, written automatically.

Step 3: Get the Declarative Elements Right

These are the calls a person makes about each product, including HTS classification, country of origin, valuation methodology, and whether antidumping or countervailing duties apply.

Get one wrong, and every number downstream is also wrong. A misclassified part becomes the pattern CBP’s model flags across every entry that carried it.

How 3rdwave does it: We keep these decisions in the maintained product and account masters as full product profiles rather than as codes on a spreadsheet. Classification, origin, valuation basis, and ADD/CVD applicability get applied the same way on every entry, so the same part doesn’t get classified three different ways across three filings.

Step 4: Redo the Transformations Yourself

This is where the entry is built from the declarations. It’s also where the quiet errors live, errors related to quantity conversions, tariff unit conversions, duty calculations, MPF and HMF, line consolidations, etc.

The commercial invoice lists 100 at $5 each. The entry shows 45.83 dozen, but the value doesn’t reconcile. Skip these conversions, and you’re giving your broker 100% trust rather than validating their work.

How 3rdwave does it: The platform runs every one of these calculations as part of reconstructing the entry. Quantity and unit conversions, duty, MPF, HMF, and line consolidations are computed from your source data rather than lifted from the filing. The math that is merely eyeballed in a manual audit is comprehensively completed in ours.

Step 5: Reconcile Line-By-Line Against What Was Filed

Put your reconstruction next to the broker’s 7501 and 3461, line by line. This allows you to flag every difference.

A delta is either an error in the filing or a gap in your own data, and both are worth knowing before CBP knows. Tolerance for “close enough” is what got the old process in trouble. Close enough is where the penalty lives.

How 3rdwave does it: 3rdwave compares its calculated entry against what was actually filed and surfaces every discrepancy. You don’t read two documents side by side, hunting for mismatches. You get the lines that don’t agree, so your team works the ones that matter instead of the ones that don’t.

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Step 6: Check Your Process (Not Just the Numbers)

Correct numbers filed late are still a problem. So is a correct entry with no documentation on file.

Confirm the filing was timely, confirm the documents are where they belong, and confirm your SOPs were followed. Being right isn’t always enough now. CBP cares about process, and a clean record is part of being defensible.

How 3rdwave does it: Because every document and entry lives in one timestamped repository, the platform can flag a late filing, a missing document, or a broken step in your process, not just a bad number. The audit covers whether the work was done right, not only whether the figures add up.

Step 7: Do This on 100% of Entries (Inside the 10-Day Window)

This is the standard that ties the previous six steps together. This process addresses every entry and audits it in time to file a correction before it locks.

A sample protects the entries you happened to pull, but it does nothing for the one that gets flagged.

How 3rdwave does it: This is where software stops being a convenience and becomes the only option. 3rdwave audits 100% of your entries across every data element within the 10-day window. There’s no sampling, no backlog, and no waiting for quarter-end. Your team moves from re-keying entries to resolving the exceptions the platform surfaces.

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Automate These 7 Steps With 3rdwave

CBP’s use of AI across the entire ACE database has transformed customs compliance and auditing work. Your team needs to respond by changing its SOPs.

Do the math on your own volume. With 3rdwave, every entry, every line, and every conversion gets fully checked within the 10-day window. No team with a spreadsheet can hit that. Ours does it automatically, which is the whole reason we built it.

The 7 steps outlined above are the new standard. You can spend a lot of time and money trying to automate it in-house — or you can use 3rdwave as your organization’s turnkey solution for avoiding CBP scrutiny.

If you want to see what a real audit turns up on your own entries, I’m easy to find.

Reach me at grant@3rdwave.co, or connect with me on LinkedIn.