About the Webinar
CBP’s new interim final rule on importer of record (IOR) requirements represents a significant change for both U.S. and non-resident importers, as well as the customs brokers that serve them. While designed to provide new requirements for foreign IORs, the rule also creates significant new qualification and verification standards for U.S. importers, imposes increased due diligence and recordkeeping responsibilities on customs brokers, establishes CTPAT-related requirements for non-resident IORs, and potentially increases brokers’ exposure to penalties under 19 U.S.C. § 1592. Meanwhile, CBP is actively voiding importers of record for inaccurate data on the 5106 Importer Identity Form.
This webinar will break down what importers and brokers need to know, including who qualifies as a U.S. IOR, the documentation brokers will be expected to review and retain, how the new rules affect non-resident importers, and what CBP’s heightened enforcement framework could mean in practice. We’ll also discuss the implementation timeline, opportunities to comment, and the option for brokers to request additional time to comply.
Speakers
LENNY FELDMAN is a Managing Partner, Operating Committee with Sandler, Travis & Rosenberg, P.A., resident in the Miami office. He previously co-chaired the twenty-member Customs and Border Protection’s Commercial Customs Operations Advisory Committee, providing strategic recommendations directly to CBP, Homeland Security and Treasury executives on issues such as forced labor, intellectual property rights, e-commerce policy, trade partnership programs, enforcement and facilitation mechanisms, and regulatory reform. He currently serves as General Counsel and Customs Counsel to the National Customs Brokers & Forwarders Association of America (NCBFAA). He also serves on the board of governors of the American Association of Exporters and Importers and as one of their delegates to the World Customs Organization Private Sector Working Group in Brussels.
PAULA M. CONNELLY is a Senior Member of Sandler, Travis & Rosenberg, P.A., located in the Boston area. She has over 25 years of experience in customs and international trade matters. She works with importers and exporters to address and resolve import and export compliance issues.
Key Topics
- Who will qualify as a U.S. importer of record under the new standards
- How CBP intends to evaluate an importer’s U.S. presence, ownership, assets, and financial standing
- New due diligence, verification, and five-year recordkeeping obligations for customs brokers
- Requirements affecting non-resident IORs and the role of CTPAT validation
- Expanded penalty and enforcement risks for importers and customs brokers
- The rule’s effective date, opportunity to submit comments, and the process for brokers to request delayed compliance
- Avoiding the Void – Steps to take to ensure 5106 data is accurate to keep IOR numbers intact
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