The Customs Trade Partnership Against Terrorism (CTPAT) is open to members of the trade community who demonstrate a commitment to practices that help to secure the supply chain. Training is a critical component of that commitment. CTPAT members must establish and maintain a comprehensive security training and awareness program. Personnel of CTPAT members must understand the threats to the supply chain and their role in protecting it. Typically, CTPAT members should have general security awareness training that they provide to a wide audience and specialized training that is presented to personnel in more sensitive positions.
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.
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.