U.S. Customs and Border Protection (CBP) Management By Account Webinar

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1 U.S. Customs and Border Protection (CBP) Management By Account Webinar Cynthia Whittenburg Director, Trade Facilitation and Administration Office of International Trade Steven R. Graham International Trade Liaison Trade Relations Office of the Commissioner, CBP Lawrence Fanning Assistant Port Director, Trade San Diego, Office of Field Operations Leon Hayward Assistant Director, Field Operations, Trade and Cargo Security, New York, Office of Field Operations Bruce Ingalls Director, Revenue Financial Operations Office of Administration Thomas Overacker Supervisory National Account Manager Office of International Trade Cherie Parsons Supervisory Supply Chain Specialist Office of Field Operations

2 Management By Account Account Executive 2

3 Spectrum of Traders Bulk of CBP Resources Bulk of Incentives High Risk Unknown Generally Compliant Trusted Most Trusted Enforce Discourage Gain Compliance or Stop Intervene to ascertain risk level Build Compliance or Stop Less interaction Trust, but verify Account Manager Facilitation Account Executive Team Gold Key Transactional Interaction Account Interaction 3

4 Account Executive Functions 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 4

5 Management By Account Centers of Expertise

6 Center of Expertise Purpose 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; and embrace 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 6

7 CoE Prototype 1 The CoE will incorporate the knowledge to address issues that arise for the particular industry, performing the following overarching functions: Targeting Facilitation Oversight Policy Authority extends to advice and coordinating activities that impact port operations. 7

8 CoE Prototype 2 CoE structured to leverage end-to-end visibility of account to fully aggregate risk management, strengthen security, facilitate low risk trade, ensure swift and consistent enforcement, and increase efficacy of CBP s processes Will perform the following overarching functions: Risk management Account validation Enforcement Customer Service Uniformity Direct line authority over operational and tactical activities 8

9 Management By Account Risk-Based Account Management

10 Support Trusted Partners Provide a single point of contact for all CBP trade related issues Coordinate, task and direct CBP activities that impact trusted partners Oversee trusted partner activities to ensure continued adherence to partnership program requirements Develop and implement action plans to raise and maintain compliance Provide guidance on CBP programs and initiatives Resolve issues of national scope 10

11 Risk-Based Account Management 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 11

12 Collaboration LSS NAM Industry Regulations & Rulings HQ Regulatory Audit Ports NTAG CTAC C-TPAT National Account Managers Entry Specialists Import Specialists Program Managers Paralegal Specialists Drawback Specialists Headquarters CBP Officers CBP Attorneys Regulatory Auditors National Import Specialists International Trade Specialists Supply Chain Security Specialists National Targeting Analysis Group Laboratories and Scientific Services Commercial Targeting and Analysis Center 12

13

14 Management By Account Single Partnership Program 14

15 Single Partnership Goals Streamline partnership application process Increase efficiencies through closer connectivity and communication between various CBP Partnership Programs Decrease cycle time for multiple program approval Recognize partners who demonstrate a commitment to security and compliance Extend CBP partnership efforts in size and scope through partnering with Other Government Agencies (OGAs) 15

16 Single Partnership Options Trade System/Single Application Process Partnership Alternatives Gateway Program Model Open Program Model Unified Program Model Recognition Program Extended Partnership 16 16

17 Trade System Single portal system to capture and forward application data to the respective program verifiers Communication interface with the trade on partnership issues Allow for integration of program status and activity to CBP users end-to-end visibility for partnership participation Leverage resources to create an Importer Self-Assessment (ISA) Portal for more effective program tracking and management 17

18 Trade System Efficiencies One system/password for trade end users Single electronic input of common data / reduction in redundant data input Direct routing of application and back-up materials to program verifiers Use with OGA/ISA agreements or OGA partnership programs Use with Mutual Recognition Agreements Two way communication between partners Version

19 Trade System Process AEOs C TPAT ISA PIP Partnership Exchange OGAs Trade System Alert FAST Trade Applies to C TPAT, PIP, and ISA 19

20 Partnership Alternative 1: Gateway Program Model Access to partnership programs flow through certification in the Customs-Trade Partnership Against Terrorism (C-TPAT) program Importer/Carrier selects which program(s) to apply on a single application. Application would include C-TPAT, Free and Secure Trade (FAST), ISA, Importer Self-Assessment Public Safety (ISA-PS), or any combination of available programs Processing & verification of FAST, ISA, & ISA-PS would be held until C-TPAT certification Version

21 Gateway Program Model Importer Carrier C-TPAT C-TPAT advantages FAST Importer ISA C-TPAT & ISA advantages ISA-PS, Potential new OGA programs Version

22 Partnership Alternative 2: Open Program Model Applicant has option to join one or any combination of programs Importer/Carrier selects which program(s) to apply on a single application. Application would include C-TPAT, FAST, ISA, ISA-PS, or any combination of available programs C-TPAT prerequisite is not required for ISA Processing for C-TPAT or ISA approval could start concurrently C-TPAT and/or ISA is a prerequisite for derivative programs such as FAST and ISA-PS Version

23 Open Program Model Carrier C-TPAT C-TPAT advantages FAST Importer ISA C-TPAT/ISA ISA advantages C-TPAT & ISA advantages ISA-PS, potential new OGA programs Version

24 Partnership Alternative 3: Unified Program Model Combine C-TPAT and ISA into a single partnership program Must meet security and trade compliance requirements Note: Implications with legislation / Mutual Recognition Agreements Rejected by COAC 24

25 Partnership Recognition Trusted partners demonstrate the highest levels of commitment to trade security and compliance by committing to controls which meet or exceed minimum standards and through program participation with CBP Trusted partner defined as: C-TPAT tier 2 or tier 3 participant; ISA participant; and meets its financial obligations with CBP 25

26 Extended Partnership COAC concept of single partnership Create certification programs with OGAs to facilitate release in conjunction with partnership criteria Enhance coordination between CBP and OGAs that can impact release of merchandise subject to OGA requirements 26

27 27

28 Management By Account Simplified Entry Process

29 Simplified Entry Processing Goals 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 29

30 Concepts Under Review Unified / Concurrent Importer Security Filing (ISA) and Entry Filing Perform cargo selectivity sooner in the process to provide an earlier cargo examination / clearance notification Periodic Entry Summary Use of Import Activity Summary Statement (IASS) to allow trusted partners to file entry summary data on a periodic basis (reference 19 USC 1484). Pre-Filed / Forecasted Information Account based releases utilizing pre-filed or forecasted information, with minimal data at cargo release and all remaining data at entry summary 30

31 Periodic Entry Summary Concepts 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 31

32

33 Management By Account Simplified Financial Processing 33

34 Agenda Short Term Proposals: 1) Modernize the Bill Form 2) Stale Checks 3) ACH Application by Account Long Term Proposals: 1) Electronic Periodic ebilling 2) Expanded Periodic Monthly Statement (PMS) 34

35 Modernize the Bill Form Proposal: Modernize CBP Form 6084 by Eliminating the carbon-paper Including a tear-off portion and return envelope for ease of payment and processing Outcome: Trade will have a legible bill and be able to pay the correct amount the first time Reduces shortages and overages Standardizes handling for CBP and the trade. Reduces rework for CBP and the trade 35

36 Stale Checks Proposal: CBP receives notice from the Department of Treasury when refund checks have not been cashed by members of the Trade within 15 months of the check issue date. These are generally referred to as stale checks. CBP is proposing to post a listing of stale refund checks on the CBP.gov website to allow members of the trade the ability to identify refund payments owed to their company Outcome: CBP will be able to get undeliverable refunds to the correct companies Reduces letters being mailed to the trade Establishes one single source for the trade to look for missing refunds Improves service to the Trade by providing them with web-based access to unclaimed refund payments Eliminates the need for CBP to search for information related to the importer of record 36

37 ACH Application by Account Proposal: CBP would like to provide the trade the ability to file their ACH application electronically and to initiate their own changes via a CBP.gov website Outcome: Trade will be able to manage their own Automated Clearinghouse (ACH) application Reduces paperwork Reduces delays in the application process Provides for change capability electronically 37

38 Electronic Periodic ebilling Proposal: Initiate ebilling Electronic periodic statements for supplemental duty bills issued to trade Payments to CBP made via ACH or possibly credit card Expand to estimated duties and refunds Outcome: Trade will obtain a comprehensive electronic bill that can be paid via ACH/credit card Reduces paperwork Reduces lost bills Reduces overall costs Expedites collections 38

39 Expanded Periodic Statement Proposal: Extend the number of days in which importers must pay estimated duties by requiring payment with 30 calendar days following the month in which the merchandise is entered. Require an increased bond (20%) Interest bearing escrow account Stagger the payment date for each importer. Outcome: Potential benefits would include: If escrowed, bond may be reduces or eliminated for revenue purposes. Interest bearing accounts for the trade. Only available to trusted partners 39

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