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Continuous Customs Bonds
Customs and Border Protection (CBP) requires a bond to be on file for all import entries and as of January 26, 2010, for all ISF transmissions. The options are either to use a single transaction bond (STB) that covers only one shipment/transaction or a Continuous Bond that covers all import entries & ISF's in a 1-year period. Continuous bonds can be renewed year to year.
Face value of the continuous bond must cover 10% of estimated duties for a 12-month period with a minimum bond value of $50,000, and face value of the STB must cover at least the sum of the value plus the outlay due to CBP (duties, taxes, etc). Using a continuous bond could speed up clearance of merchandise since CBP always requires entry documentation to be reviewed when a single bond is used, but an import entry filed with a continuous bond can have "paperless" release.
It is now even more important for importers to have a continuous bond on file with CBP. If the importer does not have a continuous bond, not only is a STB required for the entry of merchandise, but a separate STB is required for the filing of the mandatory ISF for ocean import shipments.
More information regarding the bond requirement and other ISF regulations can be found in the updated ISF FAQ that Customs recently published on their website:
http://www.cbp.gov/linkhandler/cgov/trade/cargo_security/
carriers/security_filing/10_2faq.ctt/10_2faq.doc
Export Compliance: FAQs in Defense Trade
The following page on the Department of State's DDTC (Directorate of Defense Trade Controls) website has links to documents containing answers to frequently asked questions. The content of the documents is based on questions received most frequently by the DDTC Response Team. DDTC believes that the links will provide a valuable resource for the defense export community.
Topics covered include commodity jurisdiction, support documentation, D-trade and electronic submission of agreements.
Please visit the following link to the DDTC FAQ page for more information:
http://www.pmddtc.state.gov/faqs/index.html
BIS Compliance Guidelines
On February 22, US Department of Commerce, Bureau of Industry and Security (BIS), Office of Exporter Services, Export Management and Compliance Division placed a Compliance Guidelines document on its website. The Guidelines are intended to assist companies in the development of an operational program compliant with the Export Administration Regulations (EAR) and to develop written Export Management and Compliance Program (EMCP) guidelines. Use of the document will promote efficient export compliance practices.
Please visit the link below to access the BIS Compliance Guidelines:
http://www.bis.doc.gov/complianceandenforcement/emcp_guidelines.pdf
Elimination of the Social Security Number (SSN) as an Identification Number in the Automated Export System (AES)
In the September 2009 issue of the AIT eNewsletter, we discussed the interim final rule regarding the use of social security numbers in the Automated Export System. On February 22, 2010, the U.S. Census Bureau published the final rule, which will be effective on March 24, 2010.
According to the rule, all U.S. Principal Parties in Interest (USPPI) or U.S. authorized agents who reside or have an office located in the U.S. can no longer use an SSN for AES transmissions and must instead file using an Employer Identification Number (EIN) or Dun and Bradstreet Number (DUNS).
The final rule as published in the Federal Register also answers questions that have been brought up by the trade in response to the interim final rule.
The final rule can be found by visiting the following links:
Text: http://edocket.access.gpo.gov/2010/2010-3365.htm
PDF: http://edocket.access.gpo.gov/2010/pdf/2010-3365.pdf
CBP Trade Symposium 2009
Customs has posted the agenda and multiple presentations from Trade Symposium 2009 on its website:
http://www.cbp.gov/xp/cgov/trade/trade_outreach/presentations09/
This link provides a great resource for quick overviews of CBP initiatives. Slideshow presentations have been posted for most of the sessions, which cover topics including ISF, C-TPAT, Customs Rulings, and ACE.
If you have any questions or comments regarding the Compliance eNewsletter,
please contact Paul Codere from the Customs Brokerage Department. |
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