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CBP’s New York/Newark port issued its informational pipeline 14-024-NWK on August 4, 2014 advising they will immediately begin a “three strike” policy to enforce ISF violations. Refer to our July 14 posting for CBP’s sample violation letter.
CBP’s San Francisco port issued a notice on July 15 advising they will focus on ISF-10 enforcement for importers without the required ISF.
CBP has released a sample warning letter that it may use when notifying ISF importers of violations, consistent with their current “three strike policy.” The sample letter can be found here. This letter is intended to make importers aware of compliance issues pertaining to ISF filings, providing them an opportunity to correct issues and avoid liquidated damage claims for recurring errors. Roanoke Trade encourages ISF importers to work closely with their customs brokers on ISF filings to assist with mitigating ISF exposures.
It’s been seven weeks since CBP’s internal memo to seaports resuming limited liquidated damage (LD) enforcement on ISFs. NCBFAA and the International Trade Surety Association (ITSA) requested a copy of the directive but CBP has declined to provide it. CBP maintains that an FAQ Addendum posted to their website sets forth the pertinent elements of the directive. Regarding the resumed enforcement phase: CBP has adopted a “three strikes” policy. Ports must undertake “informed compliance” outreaches to importers via phone, email, or letter for the first three (nationwide) violations. LD cases may be forthcoming beginning with the fourth violation. The three strikes threshold […]
Effective May 13, 2014, and continuing for one year, Customs and Border Protection (CBP) announced an amendment to its Importer Security Filing (ISF) Enforcement Strategy. As a follow-up measure, CBP issued an ensuing FAQ document which is an extension of the one-year review period that began July 9, 2013. CBP has modified its approach pertinent to the enforcement of ISF-10 filings. Ports will now implement enforcement actions for the most severe violations, such as ISFs that are significantly late or have gone missing. Tardiness is relative to the length of ocean voyage to the U.S., but the focus is also on the degree […]
The trade community’s interest in ISF developments remains high. Considering the sweeping impact of this program upon brokers, importers, and others, this is no surprise. Has there been a great deal of ISF discussion over the past seven months? Yes. Have there been a many substantive changes? Not really. As a follow-up to an ISF enforcement update Roanoke prepared for its clients and colleagues late last summer, we have prepared a brief status report on ISF administration. Should you have any questions, please submit them via email to Dave Jordan at dave.jordan@roanoketrade.com so he may respond to you. Or you may contact your Roanoke service office […]
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