The Executive Assistant Commissioner of U.S. Customs and Border Protection (‘CBP’) recently wrote that Fiscal Year 2023 would see CBP placing greater focus on the issue of trade-based money laundering (‘TBML’). CTPAT members should make note of this, as there are CTPAT Minimum Security Criteria that address TBML.
The US Government has increased its efforts to prevent goods produced wholly or in part by forced labor from entering the United States. This has taken the form of legislative action through the passage of the Uyghur Forced Labor Prevention Act (UFLPA) and procedural actions like the use of Withhold Release Orders (WROs). As a natural extension, CBP has also enhanced forced labor requirements in the CTPAT Program.
Topics: Trade Compliance, CTPAT, Forced Labor
Recently, I had to provide someone with a list of the top ten CTPAT Minimum Security Criteria that I thought were the most critical. This was not an easy exercise. As any importer who is a CTPAT member knows, there are 140 different criteria, and each one is important, especially the required ones.
As 2020 winds down, the first year of C-TPAT’s new Minimum Security Criteria (MSC) is coming to a close. The new MSC’s went into effect at the beginning of the year, and in early June, the C-TPAT portal was updated to reflect these new criteria. Having worked with several C-TPAT members as they updated their programs, there are a handful of observations and best practices that I wanted to share.
On November 27, 2019 Customs uploaded the final version of the new CTPAT Minimum Security Criteria (MSC) into their webpage and the CTPAT Portal. This is the culmination of a three-year effort to update the CTPAT criteria to fulfill legal mandates, adjust to a changing trade landscape, apply lessons learned, and adapt to ever-evolving terrorism and criminal threats.
Topics: United States
