The Customs-Trade Partnership Against Terrorism is a voluntary government-business initiative that builds cooperative relationships that strengthen and improve overall international supply chain and U.S. border security. C-TPAT is widely recognized as one of the most effective means of providing the highest level of cargo security through close cooperation with international supply chain businesses such as importers, carriers, consolidators, licensed customs brokers, and manufacturers. At CBP’s C-TPAT Conference held on January 8-9, 2013, CBP announced major updates to C-TPAT – lucky for you, I’ve recapped the highlights for you below.
Trusted Trader Program
- CBP proposes to combine CBP’s ISA program with C-TPAT. Additionally, if importers choose to be part of the Trusted Trader Program, they can take advantage of “joint validations” with other government agencies (OGA’s). CBP and TSA have already been performing joint validations for 9 months. Trade is concerned that OGA’s will go on fishing expeditions while validating and no guarantees have been made from CBP that OGA’s won’t. This is a major concern for some (rightfully so!).
- CBP is seeking comments regarding its new Trusted Trader Program. Please email any comments here.
Top conspiracy indicators to look for are:
- Anyone taking photos of entrances, fencing, hours of operation, etc..
- Anyone interested in stow plans, employee schedules, transit routes, and GPS
- Anyone in financial distress
- Anyone attempting to access a system that they have no authorization to access
- Anyone showing up to work on a day off or with large bags
- Anyone entering restricted zones without access
Use the VVTT process:
- View seal and container locking hardware
- Verify seal #
- Tug on seal to make sure it is on right
- Twist and turn seal to make sure it doesn’t unscrew.
Most Common Areas of Failed Criteria:
- Conveyance Security – tracking an monitoring 51%
- Container Security – sealing/ container inspection 49%
- Business Partners – screening and subcontracting 46%
- Personnel Security – background checks 31%
SW Border Strategies
- 86% of the time the drivers are responsible and have some involvement in conspiracies
- There were 41 seizures representing C-TPAT companies in 2012
- There are 160 underground tunnels from Mexico the U.S. or Canada to the U.S.
Evidence of Implementation
Suspensions and removals from January 2002-November 2012:
- 403 importers suspended due to validation issues
- 339 were removed from C-TPAT
- C-TPAT Manuals including all minimum security procedures
- Documentation of audits, checklists, appropriate training
- Assurance that all documentation is uploaded into the portal
- Checklists to be uploaded that are filled out (blank forms will no longer be acceptable)
- Photo and video evidence of implementation may be requested
- If you DON’T contact your CBP Supply Chain Security Specialist (SCSS) when illegal activity is detected, it is a STRIKE against you
- Only for unknown visitors
- Don’t let visitors sign themselves in!
C-TPAT Portal 2.0
- Expect changes to the portal in the summer, it’s in early prototype stages now
- You will not have to be a C-TPAT member to create a user account
- SVI numbers will go away, tracking will be done using a business name and type
- Members will have the ability to share documents
- The new structure will give you the ability to combine common security practices, this is beneficial if you have more than one user account
Thomas Winkowski, Acting COO of CBP
- Over 55% of goods entering the U.S. are from C-TPAT certified partners
- CBP is pushing for more Mutual Recognition Agreements (MRA’s)
- CBP currently has 7 MRA’s in place
- MRA’s on the horizon with Taiwan, China, Israel and Mexico
Kevin McAleenan, Acting Assistant Commissioner, Office of Field Operations (OFO)
- CBP is working on advancing benefits to C-TPAT members
- New CBP Director Lauren Koffer was announced!
Dan Baldwin, Executive Director
Currently CBP has:
- 10,452 certified partners
- 158 – CBP staffing level
- 328 – Tier 3 IOR’s
- 22,223 – Total Validations Completed since inception
Concern regarding budget and number of validations CBP will be able to complete for FY13
- In 2012 there were 822 new companies that applied for C-TPAT & 693 of those were certified
Barry Brandman, President, Danbee Investigations
Top 5 best practices:
- Must enlist senior management support
- Culture and security excellence (Don’t meet standards, exceed them)
- Apply checks and balances throughout (Anticipate that your first line of defense will fail)
- Strategically utilize security technology
- Diligently audit safeguards to expose weaknesses
If you have questions regarding submitting a C-TPAT application, C-TPAT validations, advancing in tier status, or any pending C-TPAT program changes, feel free to contact me.