JAS USA COMPLIANCE

News & Insights from JAS Worldwide Compliance

JAS Forwarding (USA), Inc.

6165 Barfield Road
Atlanta GA, 30328
United States
Tel: +1 (770)688-1206
Fax: +1 (770)688-1229

Updated Importer Security Filing (ISF) Enforcement

July 6, 2016

U.S. Customs and Border Protection (CBP) announced that it would begin tighter enforcement of either late or inaccurate Importer Security Filings (ISF) beginning June 30, 2016.  Non-compliant Importer Security Filings could result in an increase in penalties or cargo holds for importers at ports of entry.  (CSMS #14-000283)

Updated Importer Security Filing (ISF) Enforcement

CBP recently issued a CSMS for updated Importer Security Filing (ISF) Enforcement.

This new phase of ISF enforcement applies to ISF-10 shipments, not ISF-5, for ocean shipments on the water on or after June 30, 2016.

CBP-HQ provided new guidance to the ports to issue any ISF claims within 90 days of discovering the violation.

Although CBP ports will no longer be required to take a "three-strikes" approach before issuing liquidated damage (LD) claims or send these claims to CBP-HQ for review, each port will continue to have authority to manage their local enforcement posture as they do today.

Per existing policy, CBP will continue to focus on "significantly" late ISF shipments that preclude or compromise CBP's ability to target the cargo before it arrives in the U.S. For example, West Coast ports have longer ocean voyages so "significantly" late may be ISFs that are not filed within 72 hours to 5 days prior to arrival of the cargo in the U.S. Other ports with shorter voyages may focus on 24 hours prior to vessel departure (what the law requires).

We also expect CBP to focus on repeat violators which can include ISF shipments that are inaccurate because there is no bill of lading match, and/or the match was not made timely and compromised CBP's targeting prior to the cargo's arrival in the U.S.

​Although CBP delayed these enforcement changes for over a year, the webinar that CBP hosted last May still provides relevant information. We encourage you to view the CBP Webinar Recording, Presentation, Transcript, and Q&A .

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Latest News

TARIFF WEBINAR

JAS Forwarding (USA) Inc. Compliance Team is pleased to announce that we will be hosting a webinar on all things tariffs on March 25, 2025, at 3PM Eastern time.

On the agenda, we will cover Canada tariffs, Mexico tariffs, China tariffs, Steel & Aluminum, reciprocal tariffs and much more.

Our own Laurie Arnold and Scott Cassell will discuss tariffs and answer questions. Check out our webinar flyer and the link to the registration page below.

ADDITIONAL STEEL AND ALUMINUM TARIFFS

Multiple media outlets are reporting that the President will increase tariffs on steel and aluminum from Canada from 25% to 50% in response to the electricity price increases announced by the Ontario government for electricity sold to the United States.  The President noted on a Truth Social post that the increase is effective starting tomorrow, March 12, 2025.

Read our full advisory by clicking below.

DERIVATIVES

Customs and Border Protection has issued two CSMS messages, 64348288 and 64348411 providing guidance on handling of steel and aluminum derivatives including derivatives outside of chapters 73 and 76. The additional 25% duty will be applicable starting on March 12, 2025, for ALL steel and aluminum derivatives.

To read our full advisory, click on the link below.

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