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AutomationRecently conducted a survey on ACE
Working with Cynthia Allen the new Executive Director, ACE Business Office
AgricultureWorking on pest control programs such as Asia Gypsy MothWorking on a survey that will be distributed to the trade.
Air Cargo Security Working with TSA and CBP to eliminate redundancies and improve efficiency on security programs (e.g. credentialing, security checks, etc.)
BondsProviding advice on the effects of Bond Centralization. Commenting on Notice of Proposed Rulemaking (NPRM) which amends 19CFR 113 (the bond regulations).Providing feedback on CBP’s updated Bond Directive(s).
COAC Subcommittees (11th Term)
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Global Supply Chain Securityprovide feedback on the Administration’s efforts to develop a National Strategy for Global Supply Chain Security
Intellectual Property Rights EnforcementRecommended the new Continuous Bond allowing CBP to provide samples of products to rights holders for review.Working on a Prior Disclosure process for IPR violations
Importer Security FilingWorking with CBP on ISF implementation. Current issues include the “finalization” of an ISF filing (when is a filing complete?).
Trade FacilitationWorking on several trade facilitation efforts including “Management by Account”, “Centers of Excellence”, etc.
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COAC Subcommittees (11th Term)
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Spectrum of Traders
Unknown
• Intervene to ascertain risk level
• Build Compliance or Stop
High Risk Generally Compliant
Trusted Most Trusted
• Enforce
• Discourage
• Gain Compliance or Stop
• Less interaction
• Trust, but verify
• Account Manager
• Facilitation
• Account Executive Team
• “Gold Key”
Unknown
• Intervene to ascertain risk level
• Build Compliance or Stop
High Risk Generally Compliant
Trusted Most Trusted
• Enforce
• Discourage
• Gain Compliance or Stop
• Less interaction
• Trust, but verify
• Account Manager
• Facilitation
• Account Executive Team
• “Gold Key”
Bulk of CBP Resources Bulk of IncentivesBulk of CBP Resources Bulk of Incentives
Transactional Interaction Account InteractionTransactional Interaction Account Interaction
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Reduce volume and redundancy of data transmissions
Reduce post entry queries and amendments
Enable statement-based processing for entry summaries and payments
Enable CBP to focus resources on higher risks
Simplified Entry Processing Goals
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Participation by ISA trusted partners
Entry summary for single importer of record based on common data elements
Proposed due date – ten days after the last release in the specified time period (supported by Census)
Each line would represent shipments released in the period with common data elements (Harmonized Tariff Schedule (HTS), country of origin, manufacturer, surety, etc)
No change to entry summary data elements currently required
Periodic Entry Summary Concepts
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CSA program simplifies the entire border crossing process for low-risk, pre-approved companies.
Importer, carrier and driver go through an application(s) and risk assessment process with CBSA prior to approval.
Once qualified, no advance data required.
For truck mode, the driver presents three pieces of information: Carrier Code, Importer Business Number and the Driver FAST or CDRP Card. (3 Bar Codes)
All three pieces of information are scanned and a risk assessment completed by a targeting system. Once approved the delivery is authorized.
Closely Examined Canada’s “Customs Self Assessment” (CSA) Program§
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Liability for duties and taxes remains with the CSA Carrier until the shipment is delivered to the CSA Importer.
Date of delivery is the “deemed” date of release for the importer.
The Importer pays duty on a periodic (monthly) basis according to the release date.
The “Revenue Summary Form” (RSF) lists all duties and taxes owing, and all adjustments to previous reports including refunds, drawbacks, voluntary tenders, etc.
The RSF is an electronic (paperless) filing.
Canada’s “Customs Self Assessment” (CSA) Program§
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Serve as a central point of contact for trade partners in the industry sector
Create an engagement plan with trusted partner to gauge compliance while minimizing touch points
Described as a “National Account Manager on steroids”.
Leon Hayward, Assistant Director, Field Ops, Trade and Cargo Security in NYC is the pilot Account Executive for the electronics industry.
Pilot started Nov. 1st
Account Executive Functions
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Exploration of a Center of Expertise (CoE) concept of operation was initiated by the COAC
Goal of this industry-focused sub-organization will:interweave “Management By Account” throughout its operational and decision-making processes; promote trade collaboration to achieve greater transparency;recognize trusted partner commitments; andembrace the overall trade strategy
CBP will consolidate industry expertise to provide uniform treatment in the application of the law, regulations, processes, and procedures, and manage risk
Center of Expertise Purpose
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Implement a finite life span for non-trusted partners and exploit a fluid pool of account candidates based on risk
Engage and manage entities regardless of size, value or volume
Collect and analyze information to identify areas of risk
Lead activities and develop comprehensive strategies to manage risk
Initiate and carry out compliance and enforcement actions
Track and report performance results
Risk-Based Account Management§
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National Account ManagersEntry Specialists
Import SpecialistsProgram Managers
Paralegal SpecialistsDrawback Specialists
HeadquartersCBP Officers
CBP AttorneysRegulatory Auditors
National Import SpecialistsInternational Trade Specialists
Supply Chain Security SpecialistsNational Targeting Analysis Group
Laboratories and Scientific ServicesCommercial Targeting and Analysis Center
Industry
PortsNAM
HQ
NTAGCTAC
C-TPATLSS
Collaboration
RegulatoryRegulatoryAudit
RegulationsRegulations& Rulings
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Commissioner’s letter dated Oct. 21, 2010 announced a slight name change to Centers of Excellence & Expertise (“CEE”)
Pilot to develop comprehensive strategies to facilitate trade and manage risk in the pharmaceutical industry began on Nov. 1st.
Anne Maracich, Asst. Port Director, Los Angeles International will direct the pilot center.
Authority extends to advice and coordinating activities that impact port operations.
CoE (now CEE) Pilot
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