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

Steven R. Graham International Trade Liaison Trade Relations Office of the Commissioner, CBP U.S. Customs and Border Protection (CBP) Management By Account

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Page 1: Steven R. Graham International Trade Liaison Trade Relations Office of the Commissioner, CBP U.S. Customs and Border Protection (CBP) Management By Account

Steven R. Graham International Trade LiaisonTrade Relations Office of the Commissioner, CBP

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

Thomas Overacker Supervisory National Account ManagerOffice of International Trade

Bruce IngallsDirector, Revenue Financial OperationsOffice of Administration

Lawrence FanningAssistant Port Director, TradeSan Diego, Office of Field Operations

Cherie ParsonsSupervisory Supply Chain SpecialistOffice of Field Operations

Leon HaywardAssistant Director, Field Operations, Trade and Cargo Security, New York, Office of Field Operations

Cynthia WhittenburgDirector, Trade Facilitation and AdministrationOffice of International Trade

Page 2: Steven R. Graham International Trade Liaison Trade Relations Office of the Commissioner, CBP U.S. Customs and Border Protection (CBP) Management By Account

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Management By Account

Account Executive

Page 3: Steven R. Graham International Trade Liaison Trade Relations Office of the Commissioner, CBP U.S. Customs and Border Protection (CBP) Management By Account

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Spectrum of TradersBulk of CBP Resources Bulk of Incentives

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”

Transactional Interaction Account Interaction

Bulk of CBP Resources Bulk of Incentives

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”

Transactional Interaction Account Interaction

Page 4: Steven R. Graham International Trade Liaison Trade Relations Office of the Commissioner, CBP U.S. Customs and Border Protection (CBP) Management By Account

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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

Page 5: Steven R. Graham International Trade Liaison Trade Relations Office of the Commissioner, CBP U.S. Customs and Border Protection (CBP) Management By Account

Management By Account

Centers of Expertise

Page 6: Steven R. Graham International Trade Liaison Trade Relations Office of the Commissioner, CBP U.S. Customs and Border Protection (CBP) Management By Account

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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

Page 7: Steven R. Graham International Trade Liaison Trade Relations Office of the Commissioner, CBP U.S. Customs and Border Protection (CBP) Management By Account

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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.

Page 8: Steven R. Graham International Trade Liaison Trade Relations Office of the Commissioner, CBP U.S. Customs and Border Protection (CBP) Management By Account

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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

Page 9: Steven R. Graham International Trade Liaison Trade Relations Office of the Commissioner, CBP U.S. Customs and Border Protection (CBP) Management By Account

Management By Account

Risk-Based Account Management

Page 10: Steven R. Graham International Trade Liaison Trade Relations Office of the Commissioner, CBP U.S. Customs and Border Protection (CBP) Management By Account

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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

Page 11: Steven R. Graham International Trade Liaison Trade Relations Office of the Commissioner, CBP U.S. Customs and Border Protection (CBP) Management By Account

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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

Page 12: Steven R. Graham International Trade Liaison Trade Relations Office of the Commissioner, CBP U.S. Customs and Border Protection (CBP) Management By Account

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Industry Industry

Collaboration

PortsPorts

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

NAMNAM

HQHQ

NTAGCTAC

NTAGCTAC

C-TPATC-TPAT

RegulatoryAudit

RegulatoryAudit

Regulations& Rulings

Regulations& Rulings

LSSLSS

Page 13: Steven R. Graham International Trade Liaison Trade Relations Office of the Commissioner, CBP U.S. Customs and Border Protection (CBP) Management By Account
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Management By Account

Single Partnership Program

Page 15: Steven R. Graham International Trade Liaison Trade Relations Office of the Commissioner, CBP U.S. Customs and Border Protection (CBP) Management By Account

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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)

Page 16: Steven R. Graham International Trade Liaison Trade Relations Office of the Commissioner, CBP U.S. Customs and Border Protection (CBP) Management By Account

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Single Partnership Options

Trade System/Single Application Process

Partnership Alternatives

Gateway Program Model

Open Program Model

Unified Program Model

Recognition Program

Extended Partnership

Page 17: Steven R. Graham International Trade Liaison Trade Relations Office of the Commissioner, CBP U.S. Customs and Border Protection (CBP) Management By Account

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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

Page 18: Steven R. Graham International Trade Liaison Trade Relations Office of the Commissioner, CBP U.S. Customs and Border Protection (CBP) Management By Account

18Version 1.5 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

Page 19: Steven R. Graham International Trade Liaison Trade Relations Office of the Commissioner, CBP U.S. Customs and Border Protection (CBP) Management By Account

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PIP

Trade System

C-TPAT

Partnership Exchange

FAST

OGAs

AEOsISA

Trade Applies to C-TPAT, PIP, and

ISA

Alert

Trade System Process

Page 20: Steven R. Graham International Trade Liaison Trade Relations Office of the Commissioner, CBP U.S. Customs and Border Protection (CBP) Management By Account

20Version 1.5 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

Page 21: Steven R. Graham International Trade Liaison Trade Relations Office of the Commissioner, CBP U.S. Customs and Border Protection (CBP) Management By Account

21Version 1.5 21

Gateway Program Model

Importer

C-TPAT

ISA

C-TPATadvantages

C-TPAT & ISA advantages

CarrierFAST

ISA-PS,Potentialnew OGA programs

Importer

Page 22: Steven R. Graham International Trade Liaison Trade Relations Office of the Commissioner, CBP U.S. Customs and Border Protection (CBP) Management By Account

22Version 1.5 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

Page 23: Steven R. Graham International Trade Liaison Trade Relations Office of the Commissioner, CBP U.S. Customs and Border Protection (CBP) Management By Account

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Open Program Model

Importer

C-TPAT

ISA

C-TPAT/ISA

ISAadvantages

Carrier C-TPATadvantages

ISA-PS,potential newOGA programs

FAST

C-TPAT & ISAadvantages

Page 24: Steven R. Graham International Trade Liaison Trade Relations Office of the Commissioner, CBP U.S. Customs and Border Protection (CBP) Management By Account

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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

Page 25: Steven R. Graham International Trade Liaison Trade Relations Office of the Commissioner, CBP U.S. Customs and Border Protection (CBP) Management By Account

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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

Page 26: Steven R. Graham International Trade Liaison Trade Relations Office of the Commissioner, CBP U.S. Customs and Border Protection (CBP) Management By Account

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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

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Page 28: Steven R. Graham International Trade Liaison Trade Relations Office of the Commissioner, CBP U.S. Customs and Border Protection (CBP) Management By Account

Management By Account

Simplified Entry Process

Page 29: Steven R. Graham International Trade Liaison Trade Relations Office of the Commissioner, CBP U.S. Customs and Border Protection (CBP) Management By Account

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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

Page 30: Steven R. Graham International Trade Liaison Trade Relations Office of the Commissioner, CBP U.S. Customs and Border Protection (CBP) Management By Account

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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

Page 31: Steven R. Graham International Trade Liaison Trade Relations Office of the Commissioner, CBP U.S. Customs and Border Protection (CBP) Management By Account

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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

Page 32: Steven R. Graham International Trade Liaison Trade Relations Office of the Commissioner, CBP U.S. Customs and Border Protection (CBP) Management By Account
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Management By Account

Simplified Financial Processing

Page 34: Steven R. Graham International Trade Liaison Trade Relations Office of the Commissioner, CBP U.S. Customs and Border Protection (CBP) Management By Account

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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)

Page 35: Steven R. Graham International Trade Liaison Trade Relations Office of the Commissioner, CBP U.S. Customs and Border Protection (CBP) Management By Account

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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

Page 36: Steven R. Graham International Trade Liaison Trade Relations Office of the Commissioner, CBP U.S. Customs and Border Protection (CBP) Management By Account

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Stale ChecksProposal: 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

Page 37: Steven R. Graham International Trade Liaison Trade Relations Office of the Commissioner, CBP U.S. Customs and Border Protection (CBP) Management By Account

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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

Page 38: Steven R. Graham International Trade Liaison Trade Relations Office of the Commissioner, CBP U.S. Customs and Border Protection (CBP) Management By Account

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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

Page 39: Steven R. Graham International Trade Liaison Trade Relations Office of the Commissioner, CBP U.S. Customs and Border Protection (CBP) Management By Account

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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

Page 40: Steven R. Graham International Trade Liaison Trade Relations Office of the Commissioner, CBP U.S. Customs and Border Protection (CBP) Management By Account