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