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In This January Issue
Upcoming Events and Save the Date
Featured Article: Extolling the Virtues of Direct-Filing
Trade News Briefs
The Penalty Box
Goals, Objectives and Blue Skies
Quick Links
Global Training Center

C-TPAT the Road to Certification

TII Principal Michael Laden will present two half-day seminars on the Customs-Trade Partnership Against Terrorism (C-TPAT) hosted by Global Training Center.  

Two events are scheduled for 2015; Wednesday, February 25th, and Thursday, May 14th.  Both sessions begin promptly at 9:00 am (central time).  
Mr. Laden will discuss the necessary steps for building an efficient and cost-effective C-TPAT program and for attaining C-TPAT Certification or Re-Validation.

This course is perfect for those considering the merits of the program, just beginning the C-TPAT journey or as a refresher before Validation or Re-Validation.  
 
Space is limited and advanced registration is required.  

For more information or to register for this event please follow this link:   Global Training Center - The Road to C-TPAT Certification

February 11
Los Angeles Customs Brokers & Freight Forwarders Association
Anti-Dumping & Countervailing Duty

February 17 - 18
AAEI Winter Seminar
Houston, TX

February 22 - 24
ICC and USCIB Trade Facilitation Symposium
Miami, FL

February 25
C-TPAT Road to Certification Webinar

March 3 - 4
CBP ACE Software Developer Session
Washington, DC

March 15 - 19
ICPA Annual Conference
 Ft. Worth, TX

April 19 - 22
NCBFAA Annual Conference
Orlando, FL

May 6 - 8
WCO IT Conference & Exhibition
Bahamas

May 14
C-TPAT Road to Certification Webinar

May 31 - June 2
AAEI Annual Conference
Arlington, VA

June 7 - 9
ICPA EU Compliance Conference
Berlin, Germany

 

June 17 - 26

WCO Knowledge Academy

Brussels, Belgium

More Info/Register 

 

October 27 - 29

WCO 5th Technology & Innovation Forum

Rotterdam, the Netherlands

More Info/Register 

 

November 2 - 3

The 28th Annual
Global Trade Controls & Compliance Conference

London, UK

More Info/Register 

Featured Article:
Extolling the Virtues of Direct Filing
A Different Frame of Mind
By Michael Laden
If you know me, then you know I am a fervent believer that the majority of importers today should be filing their own entries directly with U.S. Customs and Border Protection (CBP). The advanced technological world we live in has fostered change within the international trade industry; and as a result the process of filing entries directly with CBP is rather easy. Today as a well-connected society, most of us do our banking online, we also file and pay our personal taxes online; and some even shop for or purchase homes and automobiles via the Internet. In keeping with this line of thinking and mindset then; if an importer has all of the necessary data elements for a customs entry (classification, value, origin and quantity) and is currently sending it to a customs broker for filing - why wouldn't it make sense to just populate the same data into an intuitive web-based Automated Broker Interface (ABI) application and file the entry directly with CBP?

Debunking the Myths about Direct Filing

"Oh, I would never take on that kind of liability," you say? You already own 100% of the liability! As the official Importer of Record (IOR) with CBP, your company, and your company alone, is responsible for the accuracy of the declarations made with CBP. Employing a customs broker to file your entries does not relieve your company of any liability for compliance with CBP laws and regulations. The obligation for an IOR to undertake "reasonable care" in its customs practices is codified in the Customs Modernization Act (Mod Act) of 1993.

"Oh my gosh, I'd need tons of extra resources to direct file our entries," you exclaim! Not so fast! If you are already auditing the customs broker's work product (as you should be) you will be able to utilize those resources for entry filing; unless of course the audit is fully automated. Additionally, I think you'll be surprised by the efficiencies you actually gain by direct-filing. Also, like any system, as familiarity increases so does productivity. Templates, parts lists and other intuitive functionality help this cause and contribute to a reduction in errors. One well-known direct-filer (a Fortune 100 company) has individuals who file and process more than 100 entries in a single eight (8) hour day.

"Well personally, I'd love to direct-file our entries with CBP, but we don't have a license or permit," you explain. All importers have the right to file their own entries on their own behalf without a customs license or permit. While it helps to have a licensed customs broker on staff, it is not mandatory. An importer however cannot file entries for another entity without having a valid Corporate Customs Broker's License.

"Geez I'd love to direct-file, but who wants to increase our odds of a CBP audit?" you challenge. Direct-entry filers are no more likely, nor less likely to receive a CBP audit. Direct-filing does not increase the probability of a CBP audit; the odds are the same either way.

"Are you kidding me? We have more than 500 suppliers in 32 countries. No way can we handle that kind of volume!" you decry. Direct-filing is not an all or nothing proposition. An importer can gradually migrate into the program in a slow and orderly manner. A filer does not need to engage or turn on all suppliers in all origins at the same time. The transition can be planned and phased-in at a your own pace.

What's In It for Us?

A lot actually! First and foremost in my mind is your compliance rate; I can almost guarantee you that it will trend higher, in many cases much higher. In my humble and professional opinion, no one will take greater care in the preparation and processing of that customs entry, than your own teammates. And, furthering this opinion, no one knows more about the product being entered, than your own teammates.  (more follows)

To read the entire article or to download an Adobe copy please follow this link:  Extolling the Virtues of Direct-Filing   
Trade Update


Happy New Year and welcome to the January 2015 edition of the Trade Update.  For most of us toiling in the realm of trade compliance, the month of January is typically a slower time of year providing us with an opportunity to perform year-end tasks.  This is also the time of year that most companies contemplate or launch new initiatives or projects.  2015 may be a little different however.  The current and ongoing labor disruptions along the U.S. west coast may cause you to be a little preoccupied with logistics.  However, the opportunity to spend one or two full days planning for the year ahead should not be missed.  So, unless you've already performed these perfunctory tasks, allow this to serve as your reminder to set aside time in the coming weeks to tidy-up and complete your 2015 planning and year-end tasks.  While you're at it, check out this month's article, "Goals, Objectives and Blue Skies" for a convenient list of year-end activities.  

Late last year, you may have noticed that we added a new "Featured Article" and "Upcoming Events" sections to the publication.  Occasionally we will accept and publish Guest Columns in the new "Featured Article" section.  If you would like to be a Guest Columnist or would like to have an article considered for publication please e-mail us.  Additionally, if you have an Event coming up that you would like added to our "Upcoming Events" section please send us a note at info@tradeinnovations.com.  

 

Please share!  Feel free to circulate our newsletter to your social media network, we appreciate the exposure and it's the only way we cultivate new readers.  Share buttons may be found in the upper left-hand corner and you can Forward this e-mail by scrolling to the bottom section.    

 

The Trade Innovations team is committed to providing timely, accurate, and unique approaches to customs and supply chain security compliance. With the growing complexity of trade compliance rules and regulations in which companies engaged in global trade must be aware, we are passionate in our efforts to keep the trade community informed.  It is in that spirit that we offer this newsletter to you.  The Trade Update is published on the first Wednesday of every month.  

   

The Trade Innovations team stands ready to assist you and you with your customs and supply chain security programs. The Principals of Trade Innovations have a broad background in customs compliance, supply chain and global security and we are confident that our approach will fit your unique challenges and opportunities.  

 

Thank you for taking time from your schedule to peruse our newsletter.  We may be reached via e-mail at info@tradeinnovations.com or by telephone at 952.975.9099.    

 

Sincerely,

 

The Trade Innovations Team  

Trade News Briefs
Relevant News for Trade Professionals

2015 Harmonized Tariff Available
The International Trade Commission (ITC) has published the 2015 edition of the Harmonized Tariff Schedules of the U.S. 

To download an Adobe copy of the 2015 Harmonized Tariff please follow this link:  2015 Harmonized Tariff Schedules of the U.S.

FMCS will Assist ILWU and PMA
The U.S. Federal Mediation and Conciliation Services (FCMS) issued a Press Release on January 5, 2015, announcing that, "In response to a joint request for assistance from the parties, collective bargaining between ILWU and PMA representatives will continue as soon as possible under the auspices of the Federal Mediation and Conciliation Service (FMCS). We are prepared and ready to render prompt assistance. Deputy Director Scot Beckenbaugh, a senior FMCS mediator with extensive collective bargaining experience in this industry, has been assigned to help the parties bring these important negotiations to a mutually acceptable resolution."

As is Agency practice, the FMCS is not releasing information regarding future meeting dates and locations. In addition, the FMCS will have no further comment at this time regarding the status or substance of the negotiations.

To dowload an Adobe copy of the FMCS Press Release please follow this link:  FMCS Press Release January 5, 2015

ADD/CVD Scam Alert
CBP has issued CSMS #14-000642 titled ""Beware of Scams to Avoid ADD/CVD Duties." Importers of items or goods subject to anti-dumping (ADD) or countervailing (CVD) duties should take special note of this Alert. According to the CBP Alert, some importers of goods covered by ADD/CVD duties have received e-mails offering a "solution" to avoid ADD and CVD.  CBP provided an example of such an e-mail:

Dear purchasing manager,

We have been exporting for many years from China, especially USA and Canada. If you need this product, please tell me, so I can quote you. 

Please do not worry about the dumping duties. This order will be operated through the intermediary trade. We will send the goods to a third country; the forwarder will repack our goods for export with other company title from that third country. It is a legit business.

Importers must be acutely aware of such offers and the trade compliance area should be providing specific ADD/CVD training to individuals who purchase, acquire or otherwise procure imported goods.  Such schemes and/or scams should be incorporated into this training, along with rebates, fraudulent description, and illegal transshipment.  Such e-mails if received should be forwarded to the importer's trade compliance area for referral to CBP and Immigration and Customs Enforcement (ICE). 

To read the entire CSMS or to review and download other ADD/CVD information please follow this link:  ADD/CVD Scam Alert  

New Format for SDN and Blocked Persons
The U.S. Office of Foreign Assets Control (OFAC) on Monday released a new format for the Specially Designated Nationals and Blocked Persons (SDN) List.  
This new sanctions list format was jointly developed by the United Nations (U.N.) and the Wolfsberg Group of International Banks in an effort to create a universal sanctions list format that can be efficiently used by governments worldwide and enhances sanctions compliance.  The new format incorporates a variety of features that ensure maximum flexibility for sanctions list creators, while also limiting the need for future changes to the underlying data specification due to the standard's adaptability.  (more follows)

To read the entire article or to download the OFAC SDN List please follow this link:  New Format for SDN and Block Parties

FSMA
FDA Food Facility Renewal for 2015
The Food and Drug Administration (FDA) Food Safety Modernization Act (FSMA), signed into law on January 4, 2011, enables FDA to better protect public health by strengthening the food safety system. Among many other changes, FSMA amended Section 415 of the Federal Food, Drug, and Cosmetics Act (FD&C Act) [21 U.S.C. � 350D], which requires domestic and foreign facilities that manufacture, process, pack or hold food for human or animal consumption in the U.S. to register with FDA. Under FSMA, all food facilities that are required to register with FDA under Section 415 of the FD&C Act must renew their registrations with FDA, every other year, during the period of time beginning on October 1 and ending on December 31 of each even-numbered year.

Beginning on January 1, 2015 any foreign food facility that failed to renew their registration by December 31, 2014 is subject to be held under Section 801(l) (21 USC 381(l)) of the FD&C Act.  (more follows) 

To read the entire article, download an Adobe copy of FDA Registration Guidance or for a link to the FDA Registration site please follow this link:  Food Facility Renewal for 2015

CBP Publishes ACE Monthly Trade Update
CBP has published the December edition of the Automated Commercial Environment (ACE) Monthly Trade Update. This 3-page document contains important articles on Upcoming Periodic Statement Dates for 2015, a Wrap Up for ACE 2014, and New and Updated ACE Webinar Recordings and Documentation.

To download an Adobe copy of the ACE Monthly Trade Update please follow this link:  CBP Publishes ACE Monthly Trade Update

Regulatory Changes Ahead in 2015 
The Office of Information and Regulatory Affairs for the Office of Management and Budget has published the fall 2014 Agency Rule List for the Department of the Treasury, the Department of Commerce and the Department of Homeland Security.  These lists contain all currently proposed new rules and regulations.  A partial list of the new regulations in the pipeline are:

* Continuing Education Requirements for Customs Brokers
* Waiver of Passport and Visa Requirements Due to an Unforeseen Emergency
* Changes to the In-Bond Process
* Amendments to Importer Security Filing and Additional Carrier Requirements
* Small Vessel Reporting System
* Air Cargo Advance Screening (ACAS)
* Exemption From Entry Requirements for Certain Department of Defense Vessels and Aircraft
* Centers of Excellence and Expertise
* Freedom of Information Act Procedures
* Prior Disclosure and Lost Duty or Revenue Demands When Penalty Claim Not Issued
* North American Free Trade Agreement Preference Override
* User and Navigation Fees; Other Reimbursable Charges
* United States-Caribbean Basin Trade Partnership Act and Caribbean Basin Initiative
* Trade Benefits Under the Caribbean Basin Economic Recovery Act
* United States--Singapore Free Trade Agreement
* CBP's Bond Program
 
To review the entire list of upcoming Regulatory Changes please follow this link:  Regulatory Changes Ahead in 2015
 
C-TPAT Portal 2.0 Deploys December 8th
CBP has deployed the Customs-Trade Partnership Against Terrorism (C-TPAT) Portal 2.0, Phase 1.  While Portal 2.0 is vastly different from Portal 1.0 the launch and subsequent transition is moving along smoothly.  

If you have not recently signed into the Portal we highly recommend that you take time to do it soon.  If signing into Portal 2.0 for the first time, you will be required to reset your password; this will be your indication that you are entering Portal 2.0.

To download an Adobe copy of the C-TPAT Portal 2.0 User's Guide please follow this link:  C-TPAT Portal 2.0 User's Guide   

Marine Fisheries Working Group
CBP issued CSMS #14-000650 on December 19, 2014, titled, "Request for Participants: National Marine Fisheries Service (NMFS)Trade/PGA Working Group."

The purpose of the NMFS ACE/ITDS Working Group will be to ensure that all stakeholders are invited to participate in a discussion of the technical solution and data elements that will be required by the NMFS in the new cargo release and control functionality of ACE/ITDS. Primarily the working group will focus on the IT related issues associated with implementing the ACE/ITDS.  The working group will consist of members of the international trade community; including trade software developers, that offer [import] commodities into the United States and which are regulated by the NMFS. Officials from the NMFS and the CBP that are working on the development and deployment of ACE/ITDS will be part of this working group.  (more follows)

For more information or to read the entire CSMS please follow this link:  Marine Fisheries Working Group 

ACE Development and Deployment Schedule
CBP issued CSMS on December 19, 2014 titled, "Updated ACE Development and Deployment Schedule Available on CBP.gov/ACE." The "ACE Development and Deployment Schedule" provides details on when upcoming ACE capabilities will be developed and deployed into production. An updates pages is also included, which lists what has changed since the last version, version 7.1, which was published in October 2014.  (more follows)

To download an Adobe copy of the ACE Development and Deployment Schedule please follow this link:  ACE Development and Deployment Schedule

FDA Entry Review Pilot Evaluation
CBP issued CSMS #14-000653 on December 19, 2014, titled, "FDA Centralized Entry Review Pilot Evaluation."  The U.S. Food and Drug Administration (FDA) is pleased to announce that the Centralized Entry Review (CER) pilot evaluation is complete. The CER pilot operated from August 12, 2013, through September 30, 2013, and employed reviewers from multiple districts who reviewed entries from fourteen ports across the country.  This program, designed to be a learning pilot, gathered a comprehensive set of performance metrics which provided valuable data regarding the benefits and challenges of conducting import entry review in a centralized structure. These findings will help to improve the import process both now and in the future.  (more follows)

To download an Adobe copy of the FDA Centralized Entry Review Pilot Evaluation please follow this link:  FDA entry Review Pilot Evaluation 

2015 Federal Holidays
CBP has issued CSMS #14-000632 listing Federal Holidays for 2015. They are as follows:

Thursday, January 1 - New Year's Day
Monday, January 19 - Birthday of Martin Luther King, Jr.
Monday, February 16 - Washington's Birthday
Monday, May 25 - Memorial Day
Friday, July 3  - Independence Day
Monday, September 7 - Labor Day
Monday, October 12 - Columbus Day
Wednesday, November 11 - Veterans Day
Thursday, November 26 - Thanksgiving Day
Friday, December 25 - Christmas Day

To read the CSMS please follow this link:  2015 Federal Holidays

FY-2014 Border Security Report
CBP published a 7-page report titled, "CBP Border Security Report" on December 19, 2014.  The report outlines CBP's enforcement efforts at, and between, U.S. ports of entry primarily related to illegal immigration.

To download an Adobe copy of the Border security Report please follow this link:  FY-2014 Border Security Report 

Late Filed ISF Transmissions
CBP has issued CSMS #14-000636 titled "Elimination of Late Filed ISF Transmissions." This updates CSMS #11-000149 issued on June 29, 2011.

Effective January 10, 2015, late ISF submissions will no longer be exempt from the bond requirement and most ISF transactions will require a bond when they are filed. To avoid delay or examination upon arrival, importers should ensure that bonds are in place to cover the ISF transaction prior to the cargo being loaded on the vessel destined for the United States.

To electronically enforce this requirement, ISF Types 5 and 6 (Late ISF-10- No Bond and Late ISF-5- No Bond, respectively) will no longer be accepted as of January 3, 2015. Updated IG documentation will be published to the CBP website shortly and has been attached to this message.

To read the entire CSMS or to send questions to CBP via e-mail regarding this change please follow this link:  Late Filed ISF Transmissions

CBP is Hiring 
CBP has issued CSMS #14-000648 titled, "CBP, Office of International Trade SES Position Opportunities."

The CSMS announced two Senior Executive Service (SES) opportunities within CBP's Office of International Trade (OT). CBP is seeking qualified candidates for two key leadership positions within OT: Executive Director, Automated Commercial Environment (ACE) Business Office and Executive Director, Regulations and Rulings (RR).

The Executive Directors for these positions play instrumental roles in ensuring that CBP fulfills its trade mission and works with our key stakeholders to advance trade facilitation and enforcement efforts that contribute to our economic competitiveness while ensuring the safety and vitality of U.S. economy. These job announcements, with additional details are now posted on USAJobs and have a closing date of January 9, 2015.  (more follows)

For more information or to read the CSMS please follow this link:  CBP is Hiring

CBP to Hold ACE Developers Conference
CBP has issued CSMS #14-000639 titled, "SAVE THE DATE: March 3-4, 2015 ACE Software Developer Session."  CBP will be conducting a Software Developer Technical Session to present upcoming programming changes for new functionality scheduled to be delivered as part of the Automated Commercial Environment (ACE).  The meeting is scheduled for Tuesday and Wednesday, March 3-4, 2015 at the U.S. Department of Agriculture (USDA) Jefferson Auditorium, 1400 Independence Avenue, SW, Washington DC.  This will be a two day session, free of charge, scheduled from 7:30 a.m. - 4:00 p.m.  (more follows) 

To register or to read the entire CSMS please follow this link:  CBP ACE Developer Conference 


$772M to settle Foreign Bribery Charges
The U.S. Department of Justice (DOJ) issued a Press Release on December 22, 2014 announcing that a French power and transportation company, pleaded guilty and has agreed to pay a $772,290,000 fine to resolve charges related to a widespread scheme involving tens of millions of dollars in bribes in countries around the world, including Indonesia, Saudi Arabia, Egypt and the Bahamas.

According to the DOJ Press Release "The company's corruption scheme was sustained over more than a decade and across several continents," said Deputy Attorney General Cole. "It was astounding in its breadth, its brazenness and its worldwide consequences. And it is both my expectation - and my intention - that the comprehensive resolution we are announcing today will send an unmistakable message to other companies around the world: that this Department of Justice will be relentless in rooting out and punishing corruption to the fullest extent of the law, no matter how sweeping its scale or how daunting its prosecution."  (more follows)

To read the entire DOJ Press Release or to download Adobe copies of case documents please follow this link:  $772M to Settle Foreign Bribery Charges

$59.4M Fine for Price Fixing ocean Rates
The DOJ issued a Press Release on December 29, 2014 titled, "Third Company Agrees to Plead Guilty to Price Fixing on Ocean Shipping Services for Cars and Trucks."  According to the DOJ Press Release a Japanese corporation, has agreed to plead guilty and to pay a $59.4 million criminal fine for its involvement in a conspiracy to fix prices, allocate customers, and rig bids of international ocean shipping services for roll-on, roll-off cargo, such as cars and trucks, to and from the United States and elsewhere, the DOJ announced.  (more follows)

To read the entire article or to download the DOJ Press Release please follow this link:  $59.4M Fine for Price Fixing Ocean Rates

$135M FCPA Penalty for Gifts to Chinese
The DOJ issued a Press Release on December 17, 2014, announcing that a wholly owned subsidiary of a New York-based cosmetics company, pleaded guilty to conspiring to violate the accounting provisions of the Foreign Corrupt Practices Act (FCPA) to conceal more than $8 million in gifts, cash and non-business meals, travel and entertainment it gave to Chinese government officials in order to obtain and retain business benefits for the company's China-based subsidiary. The company admitted the improper accounting and payments and the company entered into a deferred prosecution agreement to resolve the investigation. In a proceeding before United States District Judge George B. Daniels, the criminal Informations were filed against the company and the company's China subsidiary entered its guilty plea and was sentenced.

"For years in China the company bestowed millions of dollars in gifts and other things on Chinese government officials in return for business benefits," said U.S. Attorney Bharara. "The company's China subsidiary was in the door-to-door influence-peddling business, and for years its corporate parent, rather than putting an end to the practice, conspired to cover it up. The company has now agreed to adopt rigorous internal controls and to the appointment of a monitor to ensure that reforms are instituted and maintained."  (more follows)

to read the entire DOJ Press Release please follow this link:  $135M FCPA Penalty for Gifts to Chinese

$14M for FCPA Violations
The DOJ has issued a Press Release regarding a Grapevine, TX based provider of aircraft engine maintenance, repair and overhaul services, has admitted to violations of the Foreign Corrupt Practices Act (FCPA) and agreed to pay a $14 million criminal penalty to resolve charges that it bribed Latin American government officials in order to secure lucrative government contracts.

A criminal information, filed today in federal court in the Northern District of Texas as part of the deferred prosecution agreement, charges the company with one count of conspiring to violate the FCPA and one count of violating the FCPA's anti-bribery provisions.  (more follows)

To read the entire DOJ Press Release or to download Adobe copies of case documents please follow this link:  $14M for FCPA Violations

$2.4M for FCPA Violations
According to a December 10, 2014 Press Release, the Securities and Exchange Commission (SEC) charged a Mass.-based global manufacturer of scientific instruments with violating the Foreign Corrupt Practices Act (FCPA) by providing non-business related travel and improper payments to various Chinese government officials in an effort to win business.

The Press Release cited an SEC investigation that found the company lacked sufficient internal controls to prevent and detect approximately $230,000 in improper payments out of its China-based offices that falsely recorded them in books and records as legitimate business and marketing expenses. The payments enabled the company to realize approximately $1.7 million in profits from sales contracts with state-owned entities in China whose officials received the improper payments.  (more follows)

To read the entire SEC Press release please follow this link:  $2.4M for FCPA Violations

$837,500 Penalty for Shipment to Iran
The United States Attorney's Office for the Middle District of Pennsylvania announced on December 3, 2014 that a company and its Chief Executive Officer, are jointly liable for their involvement in a conspiracy to evade export reporting requirements and with attempting to smuggle to Iran a lathe machine in violation of U.S. export regulations.  In addition to twelve (12) months of probation, the Judge adopted the penalty imposed by the U.S. Department of Commerce of $337,500 cash and $500,000, which was suspended.

To read the entire DOJ Press Release please follow this link:  $837,500 Penalty for Shipment to Iran 

Goals, Objectives and Blue Skies
By Michael Laden
For many companies, no matter when their Fiscal Year (FY) ends; the end of the calendar year represents an opportunity to reflect upon last year, complete year-end tasks and prepare for the year ahead. As such, unless your annual goals and objectives process takes place at a different time of year, January is typically the month for tying up loose-ends and planning. The size and complexity of your operation will dictate the amount of time that'll be necessary to complete your year-end duties and get organized for 2015.

Whatever you do, don't procrastinate! Set aside time right now for completing these exercises; they're important and will pay big dividends over the entire year. Again, depending on the size and maturity of your organization, it will most likely take two (2) days or less to complete; and they may be the most important two days of the year.

Some of the activities you may be involved in during the month of January are:

*   Budgeting or setting department or personal goals and objectives
* Running year-end reports in the Automated Commercial Environment (ACE)
*  Perform some analysis on the reports to ensure that your company is maintaining a high level of compliance
*   Purging old records - Only retain the last five (5) years of records, all others except those suspended from liquidation (usually involving anti-dumping or countervailing duties), can be destroyed. While not a requirement, we highly recommend retaining all documentation on entries suspended from the normal liquidation cycle.
*  Update reference tools (download copies of the 2015 Harmonized Tariff Schedules of the U.S., update internal policies and procedure manuals, etc.)
*  Conduct Business Review Meetings with service providers
*  Plan to issue Requests for Proposal (RFP's) for logistics or customs brokerage services
* Update your company's request for manifest confidentiality with U.S. Customs and Border Protection
*   Update business continuity plans
*   Send C-TPAT surveys to supply chain stakeholders
*   Refresh your company's C-TPAT Security Profile
(more follows)

 

To read the entire article or to download an Adobe copy of the article please follow this link:  Goals, Objectives and Blue Skies