Managing Trade Compliance - Webinar 2017

+1 (416) 510-8800
Webinar
Chief Product Officer
Edward (Ned) Blinick
Managing Trade Compliance in a State of Accelerated Flux
Presented by: Dana Smalley - President

Dana M. Smalley
Dana is a President at Partners In Trade Compliance (PITC), which was founded in 2011.
Throughout her career, Dana has had oversight for both trade compliance programs within
industry, as well as served as a consultant. Dana’s experience in automated solutions,
encompasses several solutions, with most recently Oracle GTM Solution on both the industry
side as well as the consulting role. She has 23+ years of trade compliance experience, 8 of which
were spent in the Telecommunications industry. Dana’s experience covers a broad mix of both
Import and Export process support for dual-use and defense commodities.
While still a GTM practitioner, Dana successfully developed and rolled out comprehensive trade
compliance programs with a global footprint in 100+ locations in more than 50 countries.
Dana has been a strategic participant in the implementation of several global trade automation
solutions, including Oracle GTM, SAP GTS, and Livingston TSE (Vastera).
+1 (416) 510-8800 3RDWAVE.COM INFO@3RDWAVE.COM

Contents
Safe Harbor Statement
Global Trade Responsibility and Ownership
Automation Today
ACE Portal Changes
ACE Account Best Practices
Pros and Cons of Automation
Closing

Safe Harbor Statement
This presentation includes publically available data, opinions, estimates or
other information that might be considered forward-looking. While the
statements enclosed represent current judgment on what the legal
obligations currently are as of the date of this presentation, you are
encouraged to independently review all material provided herein. The
content is subject to risks and uncertainties that could cause actual results
to differ materially.

Global Trade Responsibility and Ownership

Who owns the responsibility to the regulatory compliance?
- All parties to the transaction….All of them!
No one is immune to responsibility.
When engaging in business, both domestic and foreign, everyone has responsibilities to business and
trade regulations.
• Importer
• Exporter
• Shipper
• Consignee
• Intermediate Consignee
• Seller
• Buyer
• Carrier
• Customs Broker
• Freight Forwarder
• Bank / Finance Company/s
• Government Officials

What functions of international business need to be managed?
- All of them!
Import Entry
Classification Mgmt.
Valuation
Export License
DeterminationLetter of Credit Mgmt.
Free Trade Agreement Qualification
and Utilization
Incoterms
Export
Filing
Country of Origin
Deemed Export
Screening
Post Entry
Corrections
Foreign
Trade Zone
Mgmt.
Record Retention
Gov’t Reporting
Anti-Dumping
Value Added Tax
Quota / Visa
Embargos
Documentation
Generation
Regardless of who files your entries, your responsibility remains the same!
Regulatory Responsibility Examples: US Customs Mod Act, 15 CFR 30.3, 15 CFR 732 & 736, Supliment 2 to Part 736, 19 CFR, etc.

Example of Regulatory Language: 15 CFR Part 736 & 19 CFR Part 163

Management of global trade operations can be a monumental task
- Ignorance is not an excuse!
Which one are you?
Self Blinding Overwhelmed Successful

How can a responsible party manage all of their obligations?
- Evolution has provided much better methods for processing & management of global trade
responsibilities

Automation Today

Automation Today
Automation solutions exist for both US Government and Industry

Automation Today
Industry has multiple automated solutions which can be leverage today
– Not an all inclusive list
Industry Solution Options

Question
 Does your global trade data match with the government submitted trade filings?
Broker
1
Broker
2
Broker
3
US ACE Portal
Your Global Trade
Compliance Solution
Manual or Automated
Export
Filer
1
Export
Filer
2
Export
Filer
3
Data Matches?

ACE Portal Changes

ACE Portal Changes - Evolution
https://www.whitehouse.gov/the-press-
office/2014/02/19/executive-order-streamlining-
exportimport-process-america-s-businesses

ACE Basic View
Trade Community ACE Access Options
ACE
EDI Interface
(In)
Filer Direct
in ACE
Post Filing
Data Review
EDI Interface
(Out)
User Direct
Automation
Solution
PGA / OGA

ACE Portal Changes
Key ACE Enhancements: List is not all inclusive of ACE enhancements
1. US Export filing (a.k.a. EEI or AES)
a. Direct filing within the ACE portal
b. EDI capabilities for data feeds into and out of the ACE database
2. Export Reporting (Filer transactions, USPPI transactions or USPPI agent filed routed transactions)
3. Import Entry Filing (of key import entry types – list on slide 20)
4. Import Security Filing (ISF) or a.k.a. “10+2”
5. Partner Government Agencies (PGA) filing and processing:
a. Lacey
b. Food & Drug Administration (FDA)
c. National Highway Traffic Safety Administration (NHTSA)
d. National Marine Fisheries Service (NMFS)
6. Document Image System (DIS)

ACE System Stability Viewing
Stability Status
You can view the current stability of the new features of ACE on the ACE Dashboard:
https://acedashboard.cbp.dhs.gov/

ACE Portal Mandatory Filings
Within the ACE portal today, there are noted mandatory filings which much be completed via
ACE. They are as follows:
 Electronic Import Manifests (all modes of
transportation)
 US Import Entry Types:
• 01 - Consumption
• 02 - Consumption Quota/Visa
• 03 - Consumption - Antidumping/Countervailing
Duty
• 06 - Consumption - Foreign Trade Zone (FTZ)
• 07 - Consumption Antidumping/Countervailing
Duty and Quota/Visa Combination
• 11 - Informal
• 12 - Informal Quota/Visa (other than textiles)
• 21 – Warehouse
• 22 – Re-warehouse
US Import Entry Types Cont.:
• 23 - Temporary Importation Bond (TIB)
• 31 - Warehouse Withdrawal Consumption
• 32 - Warehouse Withdrawal Quota
• 34 - Warehouse Withdrawal -
Antidumping/Countervailing Duty
• 38 - Warehouse Withdrawal
Antidumping/Countervailing Duty and Quota/Visa
Combination
• 51 - Defense Contract Administration Service
Region (DCASR)
• 52 - Government – Dutiable
• Exports
• Protests
• PGA (Lacey, FDA, NHTSA & NMFS)

ACE Portal Changes To Come
The January 14, 2017 deployment of post release capabilities are postponed, including:
 Liquidation (with the exception of the electronic posting of the Notices of Liquidation on CBP.gov)
 Drawback
 Reconciliation
 Duty deferral
 Collections
 Statements and
 Automated Surety Interface
Pursuant to the Final Rule published on December 12, 2016, CBP will post the Notices of
Liquidation on CBP.gov effective January 14, 2017 as planned.
CBP will provide updated information and a new deployment date in the near future.
https://www.cbp.gov/trade/automated

ACE Portal Changes To Come
The following US import entry types are not yet available to be filed via ACE and must be filed
via paper (non-ABI) at the local port of entry.
• 04 - Appraisement
• 05 - Vessel - Repair
• 24 - Trade Fair
• 25 - Permanent Exhibition
• 26 - Warehouse - Foreign Trade Zone (FTZ) Admission
• 33 - Aircraft and Vessel Supply (For Immediate Exportation)

ACE Portal Evolution
ACE has evolved from a import post entry visibility tool, to active government filing and release
of freight for multiple government agencies
Perspective
Have respect for the epic feat to accomplish the solution modifications to support the Executive Order
Perception
Take a look at the big picture. This was no small feat to accomplish
Patience
Be patient with both the government agencies and trade community. We are all in this together for the better.

ACE Account Best Practices

Getting The Most From The ACE System
Ensure you perform a regular review of your trade activity, and make any necessary updates to
your ACE account.
 Cross check brokerage reports vs. ACE activity vs. company records (i.e. new company activity).
 The Trade Account Owner (TAO) has responsibility (not the US Government) to ensure you have your
ACE account created and/or updated.
If you have an existing ACE import account, ensure all of your businesses and locations are also
registered for exporter visibility.
 This does not take place by default because you have an existing account
 Do not make a registration decision based on import activity. The two activities are distinctly different.
Any entity can be an exporter of record or USPPI
 List all of your address locations for “exporter” to ensure full trade visibility

Account Health Check
Check your account on a regular basis to ensure:
Accurate authorized users (i.e. change in staff or roles and responsibilities)
User access (correct granting of visibility and privileges)
EINs registration and visibility
• Once an EIN is added to the primary account, you must manually add it to the shared account holders
to grant visibility

Reporting
Important key point about visibility:
User should obtain the report data dictionary to understand the report data you’re pulling
Exports
 Legacy data is immediately available for the export reports for the last five years plus the current year
Import
 Reports in ACE will only reflect data from the date the EINs was added to your account.

Pros and Cons of Automation

Pros and Cons of Automation
Pros
• Gained efficiencies / optimizations
• Risk avoidance / reduction
• Global visibility
• Accuracy
• Cost reduction
• Opportunity for growth
• Ability to best steer your future as regulatory compliance continues to evolve
Cons
• Implementation costs
• Lack of in-house expertise
• Understanding what the data is telling you
Challenges
• Clean & consistent data / data integrity (company name & addresses)
• Missing data (classifications, values, descriptions, etc.)
• Executive management support

Closing
Questions:
 What are your business and operational goals for automation?
 Have you identified “nice to have” vs. “must have”?
 Are your automation goals realistic?
 Do you have the global data visibility needed to manage your responsibilities and mitigate your
risk?
 Do you perform self-assessments and internal audits?
 Can automation help resolve challenges, risk and trade compliance gaps?
 Who are your key automation stakeholders?
 Where do you see your business in five years from now?
“Change is inevitable, progress is optional.”
- Tony Robbins

Question
Is this you?

+1 (416) 510-8800
Webinar
Managing Trade Compliance in a State of Accelerated Flux
Presented by: Dana Smalley - President
Ned Blinick
Chief Product Officer
Blinco Systems Inc.
(416) 510-8800 ext. 234
www.3rdwavegcm.com
eblinick@blinco.com
(941) 468-1384
www.pitc2011.com
dana@pitc2011.com

Managing Trade Compliance - Webinar 2017

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