CBP Working on Prior Disclosure-Like Process for Forced Labor for CTPAT Members, Garza Says

CBP is working on a new benefit for the Customs-Trade Partnership Against Terrorism program that would allow CTPAT members to report they’ve found forced labor in their supply chain without triggering CBP penalties or additional detentions, CBP’s Manny Garza said during a webinar hosted by the agency on Jan. 27.

“It’s not a prior disclosure because prior disclosure is very specific, but we’re trying to identify something very similar to that, so that partners are not worried about disclosing that information,” said Garza, who is director of the CTPAT program.

Garza said he has been in discussions with senior leadership at CBP, including executive assistant commissioners Pete Flores and AnnMarie Highsmith of the agency’s field operations and trade offices, as well as CBP’s office of chief counsel. “Even our acting commissioner, Mr. Troy Miller, is familiar with the desire for companies to want to provide information but, at the same time, not get in trouble for providing that information,” he said.

“We are working very hard at trying to identify some way” that partners in CTPAT Trade Compliance and the CTPAT cargo security programs “can provide information to CBP without worrying about it getting issued penalties or having additional shipments stopped,” Garza said.

“We don’t have a benefit in place for that yet,” he said.