Customs Bonds

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 […]

Despite the good-faith efforts of CBP officials, there continue to be many Importer Security Filing (ISF) related questions on the minds of the international trade community. Roanoke Trade has been extensively involved in the CBP and trade dialog on ISF via its representation in and interaction with COAC, the Customs-Surety Executive Committee, the International Trade Surety Association, the NCBFAA ISF Subcommittee, and a number of other organizations. We would like to share with you knowledge we have gained from those activities but – we wish to do so in a manner that respects your time. To achieve these twin objectives, we have prepared for you […]

Starting with Importer Security Filings (ISF) due on or after July 9, 2013, US Customs and Border Protection (CBP) will begin to use liquidated damages as an enforcement tool for compliance. For over 3 years, CBP relied on outreach, education, and port examinations for non-compliant ISF Importers. The information in this notice is based on the CBP ISF Regulations, CBP ISF FAQ’s, and public statements CBP has made to media outlets and to trade groups. ISF liquidated damages arise from the bond contract. Any ISF Importer with certain continuous bonds on file (Activity Codes 1, 2, 3, 4 or 16) automatically agrees to comply with all ISF requirements. […]

Roanoke Trade, as member of the National Association of Surety Bond Producers (NASBP), represents NASBP on the Customs Surety Executive Committee (CSEC). Members of CSEC collaborated to compile an FAQ and related documents at the request of the National Customs Brokers and Freight Forwarders Association (NCBFAA). This FAQ document and appendices are posted for general information purposes. Please read the FAQ/appendices in their entirety to gain a clear understanding of what they represent and how they were formulated. Although the FAQ was prepared at the request of the NCBFAA, the posting of these documents does not imply endorsement of the data requirements […]