U.S. Customs and Border Protection states that all Customs Trade Partnership Against Terrorism members will need to comply with updated minimum security criteria by January 2020. CBP has also added two new criteria that will apply to all entities.

In May 2019 CBP released the first major update to the CTPAT MSC, adding requirements to help address the most prevalent and evolving security threats. There are new and updated criteria relating to cybersecurity, protection against agricultural contaminants and pests, prevention of trade-based money laundering and terrorism financing, and using security technology to fortify existing physical security requirements. CBP also added a recommendation that addresses social compliance programs.

CBP has now added another two criteria for all entities. The first is that CTPAT members must have a code of conduct in place, and the second is that members must initiate their own internal investigation of a security breach as soon as they are aware of the incident. CBP has also developed additional criteria for sea carrier members.

CBP states that all CTPAT members will need to comply with all updated requirements by January 2020, even though most members will not undergo a revalidation in 2020 due to the four-year validation cycle.

Finally, CBP expects the new security profile reflecting the updated MSC to be ready by June 1, 2020. In the meantime, CBP has made available Excel-based security profiles for each business entity eligible for CTPAT (importers, exporters, carriers, third-party logistics providers, etc.). CBP states that members will need to familiarize themselves with the security profile questions and then, once the new security profile in the portal has been updated, update their security profiles in the portal. 

For more information on CTPAT issues, please contact customs attorney Lenny Feldman at (305) 894-1011.

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