U.S. CBP Update on the Trusted Trader Program

Presented by:

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Housekeeping

• Please turn up your speakers if you are listening to this via your computer

• If you are unable to listen over the Internet, you can call into the webcast using the numbers located in the Info tab on your screen

• Q&A will be held at the end, please submit all questions via the Q&A box

• For those on Twitter, follow the webcast and related information using #trustedtrade

• If you would like the slides, please email us at Info@IntegrationPoint.com

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Agenda

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• Where Trusted Trader Fits with CBP’s Trade Transformation Initiatives

• Program Challenges and Considerations • Trusted Trader Phase 1 Pilot Program Overview

• Federal Register Notice (FRN)

• General Expectations for Phase 2 & 3

• PGA Integration

• Next Steps

Speaker Introductions

Diane DeJarnett

Customs & Trade Compliance Manager

Toyota Motor Sales, USA, Inc.

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Valarie Neuhart Director, Industry & Account Management

Cargo & Conveyance Security Office of Field Operations

US Customs & Border Protection

Trusted Trader Program

Trusted Trader Objective • Objective: Design a holistic, integrated trusted trader

program that seeks to address physical supply chain security, trade compliance, financial compliance and enforcement.

CBP: • CBP will more effectively evaluate whether a company is a trusted

partner for supply chain security and trade compliance. • It will serve as a step forward in integrating C-TPAT and ISA. • Increase the pool of trusted traders and redirect resources to

unknown and high risk importers. • Strive to integrate other US government trusted trader programs.

Trade:

• Reduce the up-front costs of the application, vetting, and validation processes to become a trusted trader.

• It is also meant to diminish transaction costs through enhanced incentives.

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Advancing CBP Trade Priorities

• Consistency and Harmonization

• Modernization

• Comprehensive Trusted Trader Program

• Co-Creation of Trade Initiatives

• Trade Enforcement and Revenue Collection

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Proposed Framework

• Unified approach of a single trusted trader program that will be managed in Office of Field Operations (OFO) and include:

– Leveraging the CEEs to manage trusted trader accounts

– Recognition of specific, individualized risk assessments and internal controls

– Verifiable metrics to demonstrate the benefits of being a member in the Trusted Trader Program and for CBP to measure the program’s effectiveness

• Participants will have their supply chains validated and considered for trade compliance applicability for added validation efficiencies

• Internal controls must be demonstrated upon request

• PGAs may build onto the baseline criteria with their specific program requirements

• Considering the inclusion of Non-Resident Importers (NRIs) that have an affiliated business unit staffed and operating in the U.S. or Canada

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Program Expectations Application: Unifies the current C-TPAT and ISA application processes.

Vetting: CBP will begin vetting within 30 days from receipt of the application and consider the following:

• Enforcement risks

• Compliance history

• Prior audits

• Documented system of internal controls

• Financial reviews

• Corporate history, structure, and ownership

Validations: CBP will have a cadre of CBP experts to include but not limited to Supply Chain Security Specialist (security), National Account Manger, Import Specialists (classification), Regulatory Auditors (complex accounting) and PGAs if the applicant has indicated the desire to participate in an PGA component of the program.

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TRUSTED TRADER WORKING GROUP Trade Perspective

Diane DeJarnett

Customs & Trade Compliance Manager

Toyota Motor Sales, U.S.A., Inc.

9/17/2013

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CBP Engages the Trade

• First meeting, July 2012

• Members from trade include Automotive

Aerospace

Retail

Food

Petroleum

Pharmaceutical

Carrier

Customs Broker

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New Incentives

• Short-term, Medium-term, Long-term

• A few examples (Phase One): Retroactive flagging

Exemptions from NII, unless serious concern

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What this means to me…

• Current C-TPAT/ISA participants Will be automatically transitioned into new

program

• Current C-TPAT participants (non-ISA) Option to join Trusted Trader program

including compliance portion Option to remain C-TPAT only

• Neither C-TPAT or ISA participant Option to join Trusted Trader program fully Option to join C-TPAT only Option to remain non-participant

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What changes…

• Annual updates: Completed in C-TPAT portal (Security & Trade

Compliance)

Option to complete updates at different times of year

• Validations/Revalidations: Validations (security & compliance) conducted together

Revalidation conducted at C-TPAT schedule (compliance revalidation only when deemed necessary)

• Incentives New incentives, based on level of participation

• PGA information sharing

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Broker Pre-Certification

Preparing for the Trade Compliance piece of the Trusted Trader Program?

• Nine brokers selected to participate in the pilot

• Purpose is to assist companies

Pre-certifiers will work to expedite the Trade Compliance application process for importers who choose to use their services.

http://www.cbp.gov/xp/cgov/trade/trade_programs/bsa/

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Questions & Answers

Please submit all questions via Q&A box to the right of your screen

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Thank You

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Valarie Neuhart Director, Industry & Account Management

Cargo & Conveyance Security Office of Field Operations

US Customs & Border Protection

Diane DeJarnett

Customs & Trade Compliance Manager

Toyota Motor Sales, USA, Inc.

Thank You

For more on the questions asked today, visit the Global Trade News blog at

www.IntegrationPoint.com/GlobalTradeNews

Follow us on Twitter for more updates – www.Twitter.com/GlobalTradeNews

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