Steven R. Graham International Trade LiaisonTrade Relations Office of the Commissioner, CBP
U.S. Customs and Border Protection (CBP)Management By Account Webinar
Thomas OverackerSupervisory 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
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Management By Account
Account Executive
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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
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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
Management By Account
Centers of Expertise
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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
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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.
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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
Management By Account
Risk-Based Account Management
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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
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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
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IndustryIndustry
Collaboration
PortsPorts
National Account ManagersEntry Specialists
Import SpecialistsProgram Managers
Paralegal SpecialistsDrawback Specialists
HeadquartersCBP Officers
CBP AttorneysRegulatory Auditors
National Import SpecialistsInternational Trade Specialists
Supply Chain Security SpecialistsNational Targeting Analysis Group
Laboratories and Scientific ServicesCommercial Targeting and Analysis Center
NAMNAMHQHQ
NTAGCTACNTAGCTAC
C-TPATC-TPAT
RegulatoryAudit
RegulatoryAudit
Regulations& RulingsRegulations& Rulings
LSSLSS
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Management By Account
Single Partnership Program
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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)
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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
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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
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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
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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
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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
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Gateway Program ModelImporter
C-TPAT
ISA
C-TPATadvantages
C-TPAT & ISA advantages
CarrierFAST
ISA-PS,Potentialnew OGA programs
Importer
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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
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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
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Partnership Alternative 3: Unified Program ModelCombine 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
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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
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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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Management By Account
Simplified Entry Process
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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
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Concepts Under ReviewUnified / 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
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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
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Management By Account
Simplified Financial Processing
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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)
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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
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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
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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
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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
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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