אל חברי הארגון
להלן סקירה אודות כניסתה לתוקף ביום שלישי הקרוב של יוזמת הביטחון ISF/10+2
מעיון בחומר עולה כי האכיפה המלאה לא תהייה מיידית אלא בהדרגה, תוך אימוץ תקופת סובלנות.
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בברכה
ברי פינטוב
CBP Announces Enforcement Approach for ISF/10+2
U.S. Customs and Border Protection (CBP) issued a public announcement detailing its enforcement approach of the Importer Security Filing (ISF) rule scheduled to go into “full effect” on Tuesday, January 26th. CBP plans to take a graduated escalated enforcement approach, using the first two quarters of 2010 as an informed compliance period to further review the program and give importers more time to get used to the program.
CBP says that during the 1st quarter no liquidated damages will be issued for lack of ISF or late ISF submissions. It will issue warning letters directly to the filers and their actions will be collected into data that will be used by CBP as it moves towards stricter enforcement of the filing requirements. During the 2nd quarter CBP will continue not to issue liquidated damages but will increase holds and exams if an importer does not demonstrate sufficient effort to submit the data on time. If an importer shows no efforts to file ISF, CBP may issue liquidated damages.
During the 3rd and 4th quarters CBP will be more enforcement-minded and filers should expect liquidated damages and penalties to be issued to the "Importer of Record" if ISF elements are not submitted or submitted late.
CBP promises to work with filers to resolve issues during this graduated enforcement period, but please remember that if your shipment lacks ISF data it is considered a “high-risk shipment” and is more likely to be held and examined by CBP.
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