Thank you to our friends at Roanoke Trade for this update:
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ISF Enforcement – The Time Has Come!
May 5, 2015
A week from tomorrow marks the end of the final one-year limited
liquidated damage (LD)/”three strikes” phase of a six-year evolution of ISF
enforcement. In summary, here is what will change:
CBP is conducting a “last educational outreach” via Webinar later today.
Because this event reached maximum capacity almost immediately after being
announced by the NEI and via Cargo Systems Messaging Service (CSMS), CBP has
indicated they will post a recording of the Webinar to cbp.gov and will also publish a further CSMS on full ISF
enforcement, both later this week. These links will be posted to our website
for easy access in the Emerging Matters, ISF section. In case you have not already
done so, we strongly recommend that you subscribe to receive CSMS email
notifications, here is the link.
Certain matters (among them, full vessel departure reporting,
the future of ISF-5 filings, publication of a final rule) remain unresolved
and CBP has yet to commit publicly to routinely provide copies of LD notices
to filers.
CBP’s overall common-sense approach to enforcement has continued
to prevail over the past two years. It is the hope of all concerned that this
attitude will persist in the final enforcement phase upon which we now
embark. Still, CBP’s new posture on LD is certain to yield higher claims
output. Roanoke looks forward to working with you to underwrite
responsibly and control claims exposures sensibly.
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