Background

U.S. Customs and Border Protection is proposing to significantly increase the amount of information it gathers from members of the Customs Trade Partnership Against Terrorism. Comments on this proposal are due no later than April 19.

According to CBP, the CTPAT application currently requests an applicant’s contact and business information, including the number of company employees, the number of years in business, and a list of company officers. However, CBP states that the current vetting process for prospective members based on this information has allowed companies at higher risk for committing illegal activity to become CTPAT members and enjoy the many associated trade facilitation benefits, such as having cargo facilitated through CBP ports of entry via FAST lanes and front of the line treatment, fewer CBP inspections, etc.

To better identify high-risk applicants, CBP is planning to add the following data elements to the CTPAT application.

- date of birth

- country of birth

- country of citizenship

- travel document number (e.g., visa or passport number)

- immigration status information (e.g., alien registration number, naturalization number)

- driver’s license information (e.g., state and country of issuance, number, date of issuance/expiration)

- Social Security number

- trusted traveler membership type and number (e.g., FAST/NEXUS/SENTRI/Global Entry ID)

- Registro Federal de Contribuventes Persona Fisica (for Mexican foreign manufacturers, highway carriers, and long-haul carriers only)

- IP address (for host or network interface identification and location addressing)

No additional information would be added to the CTPAT Trade Compliance application.

CBP is seeking comments on (1) whether the proposed information to be collected is necessary for the proper performance of CTPAT functions, including whether it will have practical utility, (2) ways to enhance the quality, utility, and clarity of the information to be collected, and (3) ways to minimize the burden of the collection of information on those who are to respond, including through the use of appropriate automated, electronic, mechanical, or other technological collection techniques or other forms of information technology.

For more information on CTPAT, please contact attorney Lenny Feldman at (305) 894-1011 or via email.

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