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While membership in C-TPAT is still voluntary, there is a due diligence process that members of the program must follow in order to receive the numerous benefits given to members. If you are going through your first validation or getting ready for a revalidation (normally every three years), be aware that Customs expects you, as an importer, to ensure that certain procedures are being adhered to. You must demonstrate to Customs that you are meeting the minimum security requirements, both for your domestic facility as well as for your foreign supplier and consolidator. If not, you risk suspension from the program.

Each participant has to prove to Customs that there are written, verifiable procedures in place to support their active role in CTPAT. I have listed below items which must be addressed, documented and verified in order to remain in the program:

• Invoice and packing list verification SOPs

• Visitor controls

• Shipment confirmation procedures

• Pre-file notification procedures • Warehouse receiving and shipping procedures

• Trailer security

• Container seal verifications

• IT security

• Physical procedure and access control

• Security training and threat awareness procedures

• C-TPAT manual

Customs expects your company to live up to ideals of the C-TPAT program. If your company claims to meet or exceed standards, you must be able to prove this to them. You must prove that these procedures have actively been implemented within your company. That’s not to say that some procedures don’t change within your company from time to time. If they do, simply update your web portal.

The web portal is where your CTPAT information is housed and must reflect exactly how your company operates at that specific time, and not lag from late or missing updates. Customs has also started emailing inquiries that are sent directly into your C-TPAT portal which, if left unmonitored for 90 days, will

cause suspension from the program. One way to mitigate this issue is to set up a procedure to monitor your web portal on at least a monthly basis or utilize a third-party company to manage this process for you.

I have listed below nine steps that offer suggestions for utilizing best business practices in your CTPAT program.

• Management commitment and partner with CBP

• Develop formal policies

• Establish training programs

• Conduct internal control reviews

• Create C-TPAT compliance group

• D e v e l o p c o m p l i a n c e requirements for business partners

• Establish a C-TPAT compliance program and

• C-TPAT manual to enhance the profiles of your clients

• Partner with foreign suppliers to enhance their process

• Continue the security management effort on a consistent basis and partner with CBP

Most companies that go through the process of enrolling in the C-TPAT program spend resources they don’t want to see wasted. Even if you don’t use an outside company to assist in the initial enrollment, there is still time and manpower spent on your end. It would be a shame to waste all these efforts on gaining admission only to lose it in your first or second validation.

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