On Tuesday afternoon, CBP kicked off the 2009 Trade Symposium for attendees in Washington and the inaugural webcast. On Tuesday, attendees heard good news that CBP will use informed compliance mechanisms such as warning letters and increased inspections for ISF violations starting on January 26, 2010. Acting Commissioner Ahern stated CBP would be using the least punitive methods when the full compliance phase begins. On Wednesday, this was repeated by Richard DiNucci. He also stated that CBP would be looking for evidence of progress in the implementation of ISF during the flexible enforcement period as one of the primary mitigating factors. CBP doesn’t want to hold the cargo hostage, and they don’t necessarily want your money – they want the data. Supply the data and you get the cargo. Instead of using the catch phrase from the movie Jerry McGuire - "show me the money" the new phrase for CBP should be "show me the data."
The first glitch for those attending by webcast came before the session on International Property Rights Enforcement. The webcast disappeared into cyberspace, so we missed the IPR and ISA presentations. The good news is that the ISA presentation is available on the CBP web site.
Fortunately, those of us attending by webcast were able to rejoin the live sessions starting with the keynote address by Jane Holl Lute. Next came a lively and informative presentation on C-TPAT. Key takeaways from this session include the following:
· The C-TPAT member’s responsibilities do not end after validation.
· One of the biggest reasons violations occur is that procedures were in place and NOT followed.
· It’s not over when the cargo crosses the border. A large number of violations occur in transit from the border to the final destination.
· Technology is great, but you must know how to use it
· The most commonly breached criteria are conveyance, container, business partner and personnel security.
· The highest contributing factor for breaches is internal conspiracy.
· The most frequent location of compromise is in transit from the border.
· For those with procedures in place, those procedures were not followed in 83% of the incidents.
· If you have procedure and they aren’t followed, CBP will suspend you.
· The presentation contained a great list of best practices for carriers.
To wind up the day, we heard about ISF from a variety of perspectives including representatives from importers, shippers, carriers, trade associations and brokers. A lot of great information was presented by each speaker. One comment about ISF recordkeeping caught the Wizard’s attention. The comment was made that there was no mention of recordkeeping in the ISF rule, but the trade should consider keeping related documentation for five years. CBP addresses this same issue in the ISF FAQs, but uses a little stronger language to encourage maintenance of the records.
“The new regulations do not contain specific record keeping requirements other than retention of powers of attorney (see 19 CFR 149.5(c)). However, ISF parties should retain records necessary to demonstrate compliance with ISF filing requirements. In addition, the general 19 U.S.C. § 1508 recordkeeping requirements may be applicable to the ISF filer.”
One could also argue that 19 CFR 163.1 (a) and the Appendix to Part 163 imply that all records may not be specifically listed, but if they are related to an importation, they should be maintained. We’d like to hear your thoughts on maintaining records for 10+2 filings. The Wizard would maintain them. Better safe than sorry! Along with "show me the data" we can add "show me the records."
We’ll see you out in cyberspace for the last day of the symposium on Thursday. Kudos to CBP for the stellar organization for this year’s event and to the speakers for the insightful and informative presentations
Showing posts with label CBP Trade Symposium. Show all posts
Showing posts with label CBP Trade Symposium. Show all posts
Wednesday, December 9, 2009
Wednesday, November 11, 2009
CBP News
1. CBP 2009 Trade Symposium
The 2009 Trade Symposium is scheduled for December 8 – 10, 2009. Click HERE to view the symposium topics and schedule. Registration for the conference is currently full, but CBP is offering the option to attend by webcast. For only $35, participants will be able to view and interact online.
2. Updated ABI Software Vendors List
CBP updated its ABI Software Vendors List on 11/9/2009. This list contains the company name, address, phone number and email contact information along with the types of services provided. U.S. Customs and Border Protection (CBP) only collects the information and does not provide any endorsements as to the nature, extent or quality of the services that may be provided.
3. American Recovery & Reinvestment Act Funds
Check out updates on how CBP is using the funds received from American Recovery and Reinvestment Act (ARRA). CBP appropriated $420 million for constructing 24 new land ports of entry, primarily along the northern border and making repairs to existing land ports.
4. CBP Announces New Intellectual Property Bonds
U.S. Customs and Border Protection has established new bond options for intellectual property rights (IPR) owners. The owners will use this bong to obtain samples of imported merchandise suspected of violating a copyright, trade name or trademark registered by the IPR owner. IPR owners may use either a continuous or single transaction IPR sample bond. A continuous IPR sample bond has the advantage of covering multiple IPR sample transactions, across all ports of entry with a single bond and reduces the administrative burden for CBP to track single transaction IPR bonds.
5. C-TPAT Enforcement & Appeal Process
This new document provides an overview of the reasons for suspending or removing C-TPAT members from the program. Members may be immediately removed for aggravated circumstances such as providing false information or intentionally disregarding the program’s requirements. For lesser violations, members may be suspended and provided with an opportunity to comply with the requirements in order to resume active membership.
Once a security related incident or other program violation occurs, C-TPAT officials determine the appropriate next steps on a case-by-case basis. To be reinstated into the program after an incident or violation, the company must agree to a corrective action plan that identifies specific objectives and periods within which those objectives should be reached. In addition, the company must consent to un-announced visits by C-TPAT staff to monitor progress. In the case of a failed validation, the company must demonstrate that it has successfully addressed all vulnerabilities and complied with all other requirements before being fully reinstated.
Companies that are suspended or removed may appeal this decision to CBP HQ. CBP will decide the appeal in a timely fashion.
6. CBP Updates ISF FAQ
U.S. Customs and Border Protection (CBP) recently updated its "Frequently Asked Questions" document on Importer Security Filing (ISF). The document contains new information about liquidated damages, duplicate filings, Instruments of International Trade (IIT), empty containers and garments on hangers. Information about bill of lading numbers, bonds, progress reports and U.S. Goods Returned has been updated.
The 2009 Trade Symposium is scheduled for December 8 – 10, 2009. Click HERE to view the symposium topics and schedule. Registration for the conference is currently full, but CBP is offering the option to attend by webcast. For only $35, participants will be able to view and interact online.
2. Updated ABI Software Vendors List
CBP updated its ABI Software Vendors List on 11/9/2009. This list contains the company name, address, phone number and email contact information along with the types of services provided. U.S. Customs and Border Protection (CBP) only collects the information and does not provide any endorsements as to the nature, extent or quality of the services that may be provided.
3. American Recovery & Reinvestment Act Funds
Check out updates on how CBP is using the funds received from American Recovery and Reinvestment Act (ARRA). CBP appropriated $420 million for constructing 24 new land ports of entry, primarily along the northern border and making repairs to existing land ports.
4. CBP Announces New Intellectual Property Bonds
U.S. Customs and Border Protection has established new bond options for intellectual property rights (IPR) owners. The owners will use this bong to obtain samples of imported merchandise suspected of violating a copyright, trade name or trademark registered by the IPR owner. IPR owners may use either a continuous or single transaction IPR sample bond. A continuous IPR sample bond has the advantage of covering multiple IPR sample transactions, across all ports of entry with a single bond and reduces the administrative burden for CBP to track single transaction IPR bonds.
5. C-TPAT Enforcement & Appeal Process
This new document provides an overview of the reasons for suspending or removing C-TPAT members from the program. Members may be immediately removed for aggravated circumstances such as providing false information or intentionally disregarding the program’s requirements. For lesser violations, members may be suspended and provided with an opportunity to comply with the requirements in order to resume active membership.
Once a security related incident or other program violation occurs, C-TPAT officials determine the appropriate next steps on a case-by-case basis. To be reinstated into the program after an incident or violation, the company must agree to a corrective action plan that identifies specific objectives and periods within which those objectives should be reached. In addition, the company must consent to un-announced visits by C-TPAT staff to monitor progress. In the case of a failed validation, the company must demonstrate that it has successfully addressed all vulnerabilities and complied with all other requirements before being fully reinstated.
Companies that are suspended or removed may appeal this decision to CBP HQ. CBP will decide the appeal in a timely fashion.
6. CBP Updates ISF FAQ
U.S. Customs and Border Protection (CBP) recently updated its "Frequently Asked Questions" document on Importer Security Filing (ISF). The document contains new information about liquidated damages, duplicate filings, Instruments of International Trade (IIT), empty containers and garments on hangers. Information about bill of lading numbers, bonds, progress reports and U.S. Goods Returned has been updated.
Wednesday, August 5, 2009
Customs & Border Protecton News
Today's blog provides useful information recently posted on the CBP web site.
1. CBP Announces 2009 Trade Symposium
The 2009 Trade Symposium is scheduled for December 8 – 10, 2009, and will be held at the Walter E. Washington Convention Center in Washington, DC. Additional information regarding registration procedures and symposium details will be made available in the early fall.
2. CBP Posts Schedule of Future ISF Outreach Events
CBP will offer ISF training in the following cities during the month of August
· Philadelphia, PA - Wednesday August 19, 2009
· Seattle/Tacoma, WA - Wednesday August 19, 2009
· Boston, MA - Wednesday August 26, 2009
· Houston, TX - Wednesday August 26, 2009
ISF training will take place in September for the following cities; however, the dates have not yet been announced. Click HERE to check for updates.
· Baltimore, MD
· Long Beach, CA
· Miami, FL
· Charleston, SC
· Chicago, IL
· Oakland/San Francisco, CA
· Norfolk, VA
· Newark, NJ
· Washington, DC
3. CBP Provides Guidance for Validating the Power of Attorney
Since the POA is instrumental in the movement of imported cargo into the United States, it is important for brokers to ensure the validity of each POA. To assist brokers in this effort, CBP issued some guidelines for brokers to validate the power of attorney and demonstrate reasonable care. These steps are not mandatory but do demonstrate some suggested methods for verifying validity.
· To the greatest extent possible, have POAs completed in person so the grantor’s personal identification (driver’s license, passport, etc.) can be reviewed.
· Check applicable Web sites to verify the POA grantor’s business and registration with State authorities.
· If the principal uses a trade or fictitious name in doing business, confirm that the name appears on the POA.
· Verify that the importer’s name, importer number and Employer Identification Number (also known as the Federal Tax Identification Number) on the POA match what is in ACS.
· Check whether the POA grantor is named as a sanctioned or restricted person or entity by the U.S. Government. (See the Bureau of Industry and Security, U.S. Department of Commerce.)
4. CBP Selects Brokers for Self-Assessment Pilot Program
U.S. Customs and Border Protection (CBP) selected four customs brokers from 26 applicants to participate in the Broker Self-Assessment Outreach Pilot program announced in April 2009. The BSA is based on the Importer Self-Assessment Program (ISA) initiated in 2002. CBP plans to use the pilot program to assist the agency in determining whether to formally implement the BSA program and what changes might be needed to ensure its effectiveness.
5. CBP Issues Update to ACE Portal Reports Dictionary
The second version of the ACE Portal Reports Dictionary has been completed. Formatted as a PDF file, the Reports Dictionary is available on the CBP web site. The dictionary will also available by the end of August under the “Help Folder” when running ACE Reports. There is a separate dictionary for brokers, carriers, importers and sureties.
The ACE Portal Reports Dictionary is a reference guide of the most frequently accessed Account Profile, Account Management and Transactions reports designed to enhance the understanding of reports for ACE users, to assist in identifying the report that best fulfills a particular business need and to encourage the overall use of the reporting tool. The dictionary defines each report and its corresponding data objects, making it easier for ACE users to identify specific reports to meet their data requirements. The dictionary also provides the exact location of each report in the ACE reporting tool, the categorical classification of each report, the standard report filters/prompts and a description of each data object contained in the report.
1. CBP Announces 2009 Trade Symposium
The 2009 Trade Symposium is scheduled for December 8 – 10, 2009, and will be held at the Walter E. Washington Convention Center in Washington, DC. Additional information regarding registration procedures and symposium details will be made available in the early fall.
2. CBP Posts Schedule of Future ISF Outreach Events
CBP will offer ISF training in the following cities during the month of August
· Philadelphia, PA - Wednesday August 19, 2009
· Seattle/Tacoma, WA - Wednesday August 19, 2009
· Boston, MA - Wednesday August 26, 2009
· Houston, TX - Wednesday August 26, 2009
ISF training will take place in September for the following cities; however, the dates have not yet been announced. Click HERE to check for updates.
· Baltimore, MD
· Long Beach, CA
· Miami, FL
· Charleston, SC
· Chicago, IL
· Oakland/San Francisco, CA
· Norfolk, VA
· Newark, NJ
· Washington, DC
3. CBP Provides Guidance for Validating the Power of Attorney
Since the POA is instrumental in the movement of imported cargo into the United States, it is important for brokers to ensure the validity of each POA. To assist brokers in this effort, CBP issued some guidelines for brokers to validate the power of attorney and demonstrate reasonable care. These steps are not mandatory but do demonstrate some suggested methods for verifying validity.
· To the greatest extent possible, have POAs completed in person so the grantor’s personal identification (driver’s license, passport, etc.) can be reviewed.
· Check applicable Web sites to verify the POA grantor’s business and registration with State authorities.
· If the principal uses a trade or fictitious name in doing business, confirm that the name appears on the POA.
· Verify that the importer’s name, importer number and Employer Identification Number (also known as the Federal Tax Identification Number) on the POA match what is in ACS.
· Check whether the POA grantor is named as a sanctioned or restricted person or entity by the U.S. Government. (See the Bureau of Industry and Security, U.S. Department of Commerce.)
4. CBP Selects Brokers for Self-Assessment Pilot Program
U.S. Customs and Border Protection (CBP) selected four customs brokers from 26 applicants to participate in the Broker Self-Assessment Outreach Pilot program announced in April 2009. The BSA is based on the Importer Self-Assessment Program (ISA) initiated in 2002. CBP plans to use the pilot program to assist the agency in determining whether to formally implement the BSA program and what changes might be needed to ensure its effectiveness.
5. CBP Issues Update to ACE Portal Reports Dictionary
The second version of the ACE Portal Reports Dictionary has been completed. Formatted as a PDF file, the Reports Dictionary is available on the CBP web site. The dictionary will also available by the end of August under the “Help Folder” when running ACE Reports. There is a separate dictionary for brokers, carriers, importers and sureties.
The ACE Portal Reports Dictionary is a reference guide of the most frequently accessed Account Profile, Account Management and Transactions reports designed to enhance the understanding of reports for ACE users, to assist in identifying the report that best fulfills a particular business need and to encourage the overall use of the reporting tool. The dictionary defines each report and its corresponding data objects, making it easier for ACE users to identify specific reports to meet their data requirements. The dictionary also provides the exact location of each report in the ACE reporting tool, the categorical classification of each report, the standard report filters/prompts and a description of each data object contained in the report.
Tuesday, August 26, 2008
CBP Announces Annual Trade Symposium
Mark your calendars and make your reservations! On August 26, 2008, U.S. Customs and Border Protection announced its annual trade symposium will take place Wednesday October 29 through Friday October 31. The agenda for the Trade Symposium and the keynote speaker will be announced at a later date on the CBP Web site. The CBP Trade Symposium will be held at the JW Marriott, 1331 Pennsylvania Avenue, NW., Washington, DC. Hotel accommodations have been reserved at two hotels in downtown Washington, DC.
To obtain the latest information on the Symposium and to register on-line, visit the CBP Web site. The cost is $250.00 per person, and includes all Symposium activities. Persons interested in attending are encouraged to register early, as space is limited. Registration will open to the public on or about September 2, 2008. All registrations must be made online at the CBP Web site and will be confirmed with payment by credit card only.
Monday, June 30, 2008
Annual CBP Trade Symposium Scheduled
U.S. Customs and Border Protection announced the dates for its annual Trade Symposium to be held on October 29-31, 2008 at the JW Marriott Hotel in Washington, DC. Check the CBP web site for additional information regarding registration procedures and program details that should be available in September.
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