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What To Expect In 2018
CUSTOMS IN THE NEW
ACE ENVIRONMENT
Nick Esposito
Marketing Executive
Bozeman, Montana
Trade Risk Guaranty Brokerage Services, LLC
nick.esposito@traderiskguaranty.com
1st
• Located in Beautiful Bozeman Montana
• Established in 1991
• Direct-to-Importer Business Model
• Over 10,000 U.S. Customs Bond & Marine Cargo
Insurance Clients
TRADE RISK GUARANTY BROKERAGE SERVICES, LLC
ON FACEBOOK
JOIN THE CONVERSATION
TODAY’S WEBINAR TOPICS
What is ACE?
The History of ACE
Where is ACE Now?
What to Expect in 2018
ACE OVERVIEW
WHAT IS ACE?
A.C.E - Automated Commercial Environment
• A Single Window system that all imports and exports are
processed through.
• Manual processes are streamlined and automated, and paper
is being eliminated.
• Allows the trade community to more easily and efficiently
comply with U.S. laws and regulations.
INFORMED COMPLIANCE
“Informed compliance is a shared responsibility between CBP and
the import community wherein CBP effectively communicates its
requirements to the trade, and the people and businesses subject to
those requirements conduct their regulated activities in accordance
with U.S. laws and regulations. A key component of informed
compliance is that the importer is expected to exercise reasonable
care in his or her importing operations.”
- Customs and Border Protection
THE HISTORY OF ACE
AUTOMATE OR PERISH
1984
• The Automated Commercial System (ACS) introduced.
1988
• Customs Commissioner William von Raab states “Automate or
Perish” while declaring that “by 2000 paper will be nothing
but a faint and nostalgic memory.”
Late 1990s
• Discussions leading to the creation of ACE begin
AUTOMATE OR PERISH
Early 2000s
• Creation of ACE begins to pick up speed as the Trade Act of
2002 calls for advance filing of electronic cargo information.
About 4 years ago
• Presidential proclamation issued to replace ACS with ACE.
WHERE IS ACE NOW?
THE CURRENT STATE OF ACE
• After 18 years and more than $4B of our taxpayer dollars; ACE is
nearing full deployment
• For CBP purposes it is fully deployed
• Waiting on some Partnering Government Agencies (PGA’s) to
complete their programming
• International Trade Data System (ITDS) will become the “single
window” that all International trade data passes through
THE IMPORTANCE OF MID NUMBERS
What is a MID Number?
• An alpha/numeric code consisting of 13 characters used by
U.S. Customs and Border Protection (CBP) to identify foreign
manufacturers and other exporters to the U.S.
• It is required on every CBP entry and ISF
• It allows CBP to closely monitor, and if necessary, scrutinize or
target certain manufacturers or suppliers
THE IMPORTANCE OF MID NUMBERS
CBP TARGETING
• CBP largely relies on the Automated Targeting System(ATS) to
determine if they are going to examine a particular shipment
• Every inbound shipment is given a risk score based on the ISF and
other consignment attributes and details
• Other CBP exams can be caused by random selection and
stratified where they will examine certain classes or categories of
goods for a defined period of time
CBP TARGETING
• One of the critical factors in determining if an exam is going to be
performed is the “record” of MID number shipment associated
with
• If that MID has had “priors” the likelihood of an exam is
exponentially increased
WHAT TO EXPECT IN 2018
WHAT YOU CAN EXPECT
The Current Administration
• Emphasis on enforcing existing laws
• Greater scrutiny and follow through on Antidumping,
Countervailing, and Free Trade Agreements.
WHAT YOU CAN EXPECT
The Transformation of Customs and Border Protection (CBP)
• The Triple Play
• Better data and more sophisticated tools
• Commercial Targeting and Analysis Center (CTAC)
• Centers for Excellence and Expertise (CEE)
• Combined these three changes are a strong force multiplier in
ferreting out trade compliance errors and fraud
WHAT YOU CAN EXPECT
Informed Compliance Letters
• In September a series of Informed
Compliance letters was issued to
number of large U.S. importers
• CBP wants importers to sign those
letters and return them
WHAT YOU CAN EXPECT
What to do if you receive a letter:
• Many believe that you are a strong candidate for an audit
• Focused Assessment (FA)
• Quick Response Audit (QRC)
• Undertake an immediate and thorough review of your entire
program focusing on areas of greatest risk, but leaving no
stone unturned
WHAT YOU CAN EXPECT
What to do if you receive a letter:
• If necessary, make a Prior Disclosure
• A prior disclosure is made if the person concerned
discloses the circumstances of a violation either orally or
in writing to a Customs officer before, or without
knowledge of, the commencement of a formal
investigation of that violation.
WHAT YOU CAN EXPECT
What to do if you receive a letter:
• The bottom line is; you are on CBP’s radar and they have
detected something in your data that causes them concern
• If you didn’t receive one, watch the mailroom
• Have a process in place for when a letter from CBP is
received.
KEY TAKEAWAYS
• ACE is almost fully deployed
• CBP’s new system and processing centers are catching many
more errors than they used to
• This would be a good time to review your compliance protocols
• Take Compliance Letters seriously and discuss it with executives
• If you didn’t, watch the mailbox!
COVERED IN TODAY’S WEBINAR
What is ACE?
The History of ACE
Where is ACE Now?
What to Expect in 2018
SUBMIT YOUR QUESTIONS
AND/OR FEEDBACK
• Unique Direct-to-Importer Business Model
• Save Time & Money
• Multi-Year Billing Cycles (5-Year Term for $225 per Year)
• Work with any broker or forwarder
• In-house Claims Assistance from Licensed Customs
Brokers
TRADE RISK GUARANTY BROKERAGE SERVICES, LLC
Email:
Website:
Facebook:
Twitter:
FB Group:
YouTube:
inquiry@StrixSmart.com
www.strixsmart.com
@StrixSmart
@Strix_LLC
International Trade Professionals - TRG
Trade Risk Guaranty

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Customs in the New ACE Environment: What to Expect in 2018

  • 1. What To Expect In 2018 CUSTOMS IN THE NEW ACE ENVIRONMENT
  • 2. Nick Esposito Marketing Executive Bozeman, Montana Trade Risk Guaranty Brokerage Services, LLC nick.esposito@traderiskguaranty.com 1st
  • 3. • Located in Beautiful Bozeman Montana • Established in 1991 • Direct-to-Importer Business Model • Over 10,000 U.S. Customs Bond & Marine Cargo Insurance Clients TRADE RISK GUARANTY BROKERAGE SERVICES, LLC
  • 4. ON FACEBOOK JOIN THE CONVERSATION
  • 5. TODAY’S WEBINAR TOPICS What is ACE? The History of ACE Where is ACE Now? What to Expect in 2018
  • 7. WHAT IS ACE? A.C.E - Automated Commercial Environment • A Single Window system that all imports and exports are processed through. • Manual processes are streamlined and automated, and paper is being eliminated. • Allows the trade community to more easily and efficiently comply with U.S. laws and regulations.
  • 8. INFORMED COMPLIANCE “Informed compliance is a shared responsibility between CBP and the import community wherein CBP effectively communicates its requirements to the trade, and the people and businesses subject to those requirements conduct their regulated activities in accordance with U.S. laws and regulations. A key component of informed compliance is that the importer is expected to exercise reasonable care in his or her importing operations.” - Customs and Border Protection
  • 10. AUTOMATE OR PERISH 1984 • The Automated Commercial System (ACS) introduced. 1988 • Customs Commissioner William von Raab states “Automate or Perish” while declaring that “by 2000 paper will be nothing but a faint and nostalgic memory.” Late 1990s • Discussions leading to the creation of ACE begin
  • 11. AUTOMATE OR PERISH Early 2000s • Creation of ACE begins to pick up speed as the Trade Act of 2002 calls for advance filing of electronic cargo information. About 4 years ago • Presidential proclamation issued to replace ACS with ACE.
  • 12. WHERE IS ACE NOW?
  • 13. THE CURRENT STATE OF ACE • After 18 years and more than $4B of our taxpayer dollars; ACE is nearing full deployment • For CBP purposes it is fully deployed • Waiting on some Partnering Government Agencies (PGA’s) to complete their programming • International Trade Data System (ITDS) will become the “single window” that all International trade data passes through
  • 14. THE IMPORTANCE OF MID NUMBERS What is a MID Number? • An alpha/numeric code consisting of 13 characters used by U.S. Customs and Border Protection (CBP) to identify foreign manufacturers and other exporters to the U.S. • It is required on every CBP entry and ISF • It allows CBP to closely monitor, and if necessary, scrutinize or target certain manufacturers or suppliers
  • 15. THE IMPORTANCE OF MID NUMBERS
  • 16. CBP TARGETING • CBP largely relies on the Automated Targeting System(ATS) to determine if they are going to examine a particular shipment • Every inbound shipment is given a risk score based on the ISF and other consignment attributes and details • Other CBP exams can be caused by random selection and stratified where they will examine certain classes or categories of goods for a defined period of time
  • 17. CBP TARGETING • One of the critical factors in determining if an exam is going to be performed is the “record” of MID number shipment associated with • If that MID has had “priors” the likelihood of an exam is exponentially increased
  • 18. WHAT TO EXPECT IN 2018
  • 19. WHAT YOU CAN EXPECT The Current Administration • Emphasis on enforcing existing laws • Greater scrutiny and follow through on Antidumping, Countervailing, and Free Trade Agreements.
  • 20. WHAT YOU CAN EXPECT The Transformation of Customs and Border Protection (CBP) • The Triple Play • Better data and more sophisticated tools • Commercial Targeting and Analysis Center (CTAC) • Centers for Excellence and Expertise (CEE) • Combined these three changes are a strong force multiplier in ferreting out trade compliance errors and fraud
  • 21. WHAT YOU CAN EXPECT Informed Compliance Letters • In September a series of Informed Compliance letters was issued to number of large U.S. importers • CBP wants importers to sign those letters and return them
  • 22. WHAT YOU CAN EXPECT What to do if you receive a letter: • Many believe that you are a strong candidate for an audit • Focused Assessment (FA) • Quick Response Audit (QRC) • Undertake an immediate and thorough review of your entire program focusing on areas of greatest risk, but leaving no stone unturned
  • 23. WHAT YOU CAN EXPECT What to do if you receive a letter: • If necessary, make a Prior Disclosure • A prior disclosure is made if the person concerned discloses the circumstances of a violation either orally or in writing to a Customs officer before, or without knowledge of, the commencement of a formal investigation of that violation.
  • 24. WHAT YOU CAN EXPECT What to do if you receive a letter: • The bottom line is; you are on CBP’s radar and they have detected something in your data that causes them concern • If you didn’t receive one, watch the mailroom • Have a process in place for when a letter from CBP is received.
  • 25. KEY TAKEAWAYS • ACE is almost fully deployed • CBP’s new system and processing centers are catching many more errors than they used to • This would be a good time to review your compliance protocols • Take Compliance Letters seriously and discuss it with executives • If you didn’t, watch the mailbox!
  • 26. COVERED IN TODAY’S WEBINAR What is ACE? The History of ACE Where is ACE Now? What to Expect in 2018
  • 28. • Unique Direct-to-Importer Business Model • Save Time & Money • Multi-Year Billing Cycles (5-Year Term for $225 per Year) • Work with any broker or forwarder • In-house Claims Assistance from Licensed Customs Brokers TRADE RISK GUARANTY BROKERAGE SERVICES, LLC