ISF Enforcement Update – Implementation Delayed

On March 27th, the CBSA held a Trade Chain Partner Working Group meeting and announced the following changes related to CARM’s Release 2 (“R2”), coming May 13, 2024: The minimum bond amount requirement will change from $25,000 to $5,000 for all importers with the implementation of R2. The maximum bond amount will remain capped at $10,000,000 per RM account. As a reminder, the bond amount will be calculated at 50% of the highest month of duties and taxes (including GST and all debts/accounts receivables) over the previous 12-month period. CBSA cannot keep up with the paper bond filings (we have […]

By: Lenny Feldman, Managing Partner at Sandler, Travis & Rosenberg, P.A. With the government’s continued emphasis on enforcement, it has become mission-critical for parties engaged in international trade to set their strategic offensive in place through programs such as “regulatory defense. “The administration continues to issue executive actions and regulations that increase trade enforcement by stepping up the collection of section 301, 232, and 201 tariffs as well as antidumping and countervailing duties and the prosecution of trade and customs laws violations, particularly in the de minimis space. Additionally, federal agencies have issued regulations and decisions underscoring the need for […]

By Matt Zehner, VP, Surety Information & Analysis, Roanoke Insurance Group Inc. Recently, my colleague Colleen introduced Tariffs and Bond Stacking Liability and the need for importers to monitor bond sufficiency on a regular basis, with the goal to avoid a short-notice demand from CBP to terminate and file a larger bond.  One significant reason to planning the timing of when to make use of a larger continuous bond is that by reducing the number of times the bond amount changes over time, the bond principal is able to minimize the accumulation of bond liability.  There are ancillary benefits to importers when […]