CBP Seeking Comments on CTPAT Security and Trade Compliance Info Requirements

CBP is requesting comments on new data elements meant to help with vetting members of the Customs-Trade Partnership Against Terrorism, it said in a notice. "Additional information is being collected based on CTPAT’s new vetting process as the prior vetting process was found to be insufficient in being able to identify violators," the agency said. "Not collecting this information would result in companies that are high risk for committing illegal activity to be allowed into, and continue to be part of, the CTPAT program." CBP’s National Targeting Center found the previous "vetting process to be ineffective in capturing high risk companies," resulting in such companies being "allowed to be CTPAT members and enjoy the many trade facilitation benefits of membership," it said.

Additional data elements will include date of birth, country of birth, driver's license information and a social security number to "verify the identity of an owner/upper manager within the company." The agency will also require an IP address, which will help in "identifying users/locations, as needed, for law enforcement purposes," it said. "There are also instances where users (often consultants) will try to sign the CTPAT user agreement or submit security profiles on behalf of companies, which they are not allowed to do. This leaves the company liable to the actions taken by someone not authorized to take those actions. If we are able to capture the IP address, CTPAT might be able to identify cases where consultants are using unauthorized logins or logging in using Company Officer accounts in order to make it appear that submissions are coming from a Company Officer."

CBP also outlined questions used in the CTPAT Trade Compliance program. The optional program is open to U.S. and non-resident Canadian importers that have "completed the security aspects of the CTPAT program and is in good standing." The trade compliance program applications include questions on "Business information including Company Name, Company Address, Company phone number, Company Website, Company type (private or public), CBP Bond information, Importer of Record Number, and number of employees" and internal trade compliance procedures. Also requested are company broker information, prior disclosure history and Partner Government Agency affiliation information, it said.

After approval, "the importer will be required to submit an Annual Notification Letter to CBP confirming that they are continuing to meet the requirements of the program," CBP said. "This letter should include: personnel changes that impact the CTPAT Trade Compliance Program; organizational and procedural changes; a summary of risk assessment and self-testing results; a summary of post-entry amendments and/or disclosures made to CBP; and any importer activity changes within the last 12-month period."