Importer Security Filing (ISF) Compliance Workshop ICPA Annual Conference 2014 March 25, 2014 Orlando, FL

Transcription

1 Importer Security Filing (ISF) Compliance Workshop ICPA Annual Conference 2014 March 25, 2014 Orlando, FL

2 Contact Information Albert Saphir, Principal ABS Consulting Today s ISF panel is presented and moderated by Albert Saphir Over 30 years in international transportation and trade compliance T: / E: albert@abs-consulting.net M. Craig Clark, Program Manager, Office of Cargo and Conveyance National point of contact for all ISF matters at CBP Headquarters in DC T: / E: craig.clark@cbp.dhs.gov Refer to CBP ISF website for current information Lisa Gelsomino, President/CEO Avalon Risk Management Leading provider of Customs and ISF Bonds; NCBFAA ISF Sub-committee w/ CBP ISF outreach to 2,000+ trade members, see T: / E: lgelsomino@avalonrisk.com Virginia Thompson, Senior Director of Import/Export Operations and International Trade Compliance Crate and Barrel ISF compliance from an importer perspective for one of the largest retailers T: / E: vthompson@crateandbarrel.com 2

3 M. Craig Clark Program Manager Office of Cargo and Conveyance Security CBP Headquarters 3

4 ISF Timeline ISF Action Date ISF Proposed Rule (NPRM) 01/02/08 ISF Interim Rule 01/26/09 Flexible Enforcement 01/26/09 Informed Compliance 01/26/10 ISF Enforcement 07/09/13 NPRM (ISF-5) ETA of 2/14 ISF Final Rule ETA of 8/14 CBP FAQ Update OR&R Review ISF Document 1 st notice of ISF bonds CBP 19CFR149(b) CBP ISF Interim Rule CBP ISF Web Page CBP ISF Mitigation Guidelines CBP CSMS Enforcement Message Questions or comments to: security_filing_general@cbp.dhs.gov CBP FAQ dated 07/09/10 4

5 ISF by the Numbers January 26 November 23, 2009 January 26 September 21, million ISF-10s 6.2 million ISF-10s 1,900 ISF Filers (90% customs brokers) 2,350 Filers 99,700 ISF importers on file 194,000 ISF importers on file 95% importers filing ISF 97% importers filing ISF nationally January 01, 2013 December 31, ,000 vessel stow plans 10,508,000 ISF-10s 101 million container status messages 2,500+ Filers 264,000 + ISF importers on file 90%+ importers filing ISF nationally 22,000+ vessel stow plans 369+ million container status messages 82% compliance in NY/NJ 5

6 ISF Statistics and Updates Bond Statistics 10,508,000 ISFs in ,000 ISF-D Singles/Year (estimate) 99% of ISFs filed against CTBs Enforcement Statistics 7,900,000 ISFs since 7/9/13 1% result in Cargo Holds.0003% result in LD claim What about ebond? Activity Code 1 (SEB and CB) by 1/3/15 Activity Code 16 STB 3 rd in volume CBP to confirm ISF in scope by 1/3/15 What about ACE Cargo Release?* Ocean shipments effective 1/4/14 Deployment C is scheduled for 4/5/14 Will certify summary for release * ACE Cargo Release will not replace ISF, but it will allow the filer to fulfill the ISF requirements. The approach is that if we have the data in the system, the trade will not have to send it again. CBP cannot say when this will be operational it may be after Deployment C or a separate deployment just for the ISF integration. 6

7 ISF Enforcement Effective 7/9/13 ISF-10 U.S. Bound Cargo ISF-5 Transit Cargo Carrier Requirements (3461 Entries, IT, FTZ) 24 Hrs Prior to Lading* 1. Importer of Record or FTZ Number 2. Consignee Number(s) 3. Seller (Owner) name/address 4. Buyer (Owner) name/address 5. Ship to Party name/address 6. Manufacturer (Supplier) name/address 7. Country of Origin 8. Commodity HTS-6 digit level ASAP, But NLT 24 Hrs Prior to Arrival 9. Container Stuffing Location 10. Consolidator (Stuffer) name/address *Must be linked together as a lineitem at the ISF shipment level *ISFs for exempt break bulk shipments are required NLT 24 hrs prior to arrival (FROB*, IE, TE) 24 Hrs Prior to Lading* 1. Booking Party name/address 2. Ship to Party 3. Commodity HTS-6 4. Foreign Port of Unlading 5. Place of Delivery *FROB ISF-5 is required anytime prior to lading Vessel Stow Plan NLT 48 Hrs After Departure* *Anytime prior to arrival for voyages less than 48 Hrs For all vessels carrying containers Container Status Message (CSM) Data w/in 24 Hrs of Creation or Receipt ISFs must contain the lowest bill of lading number (i.e., regular or house B/L) as referenced in the Automated Commercial Environment (ACE). 7

8 B/L commonly known as the 11th data element. B/L required as part of the ISF transmission ISF Importer must provide B/L to lowest common denominator ISF Filer needs to query ACE to secure a B/L match This links ISF to Customs manifest in ACE to be visible to CBP CBP cannot target ISF without a B/L match CBP needs match 24 hours prior to arrival to conduct targeting Failure to match 24 hours prior to arrival may result in cargo hold Liquidated Damage claim also possible A B/L mismatch is an inaccurate ISF Potential for 2 LD claims, late ISF and inaccurate ISF if untimely B/L match Cap is $10,000 any one ISF transaction Bill of Lading Match in ACE 8

9 ISF Enforcement - Cargo Holds CBP expects 100% compliance since 7/9/13 Non-compliant ISFs subject to cargo holds in ACE When is CBP using the new ISF cargo holds? (<1% of cargo) When ocean cargo arrives without an ISF When an ISF is not timely filed 24 hours prior to departure When an ISF is not complete and/or missing a B/L match Entry cannot be made at ocean port without an ISF Sent to G.O. if entry is not made (manual cargo holds) 9

10 ISF Enforcement - Cargo Holds 2Q is the code for Carrier Holds Overseas Should only be used when there is a threat to national security. Any instances of CBP holding cargo or containers overseas without a 2Q code should be reported to CBP-HQ: craig.clark@cbp.dhs.gov Do not expect ocean carrier to hold cargo for non-compliant shipments. Once ISF data received, security assessment made Each port has its own process for handling manual cargo holds. Some ports don t have facilities to strip consolidated cargo when cargo is held so a single late ISF can delay an entire container. CBP does not compare ISF to Entry data; however, this may be reviewed during a cargo hold or inspection. Discrepancies that impact national security are major concern. Liquidated Damages could be assessed in addition to or instead of cargo holds. 10

11 ISF Enforcement - Port Level Port Each port will implement ISF based on local needs/resource Date LA/Long Beach 07/12/13 NY/NJ 07/19/13 Seattle 07/22/13 San Francisco/Oakland 07/25/13 Baltimore 08/05/13 Notices are similar, contact local port for details Port Notice Link LA Public Bulletin Pipeline NWK CBP Trade Information Notice WA Notice BWI Port Information Notice LA/Long Beach has been most unique The high volume of means LA/LB has to stratify its ISF enforcement more than some other ports. Effective 10/7/13, LA/LB is holding cargo that arrives without an ISF 48 hours prior to arrival; other ports adhere to 24 hours prior to departure. Each port handling ISF enforcement differently due to local resources but all LD claims are reviewed by CBP-HQs during this measured period. 11

12 C-TPAT Importers When importers are C-TPAT certified Consolidate with other C-TPAT cargo as best practice. Load cargo that has ISF acceptances in same container. These best practices can help avoid cargo holds. How can the Trade better identify C-TPAT importers? You must participate in C-TPAT to have access to the C-TPAT Status Verification Interface to search participants. Also visit: A record of ISF non-compliance will threaten your C-TPAT status and/or participation. 12

13 ISF Enforcement - Liquidated Damages When and Why Will a Liquidated Claim Get Issued? ISF must be filed timely, accurately, and completely. If not, CBP may assess liquidated damages of $5,000 per violation subject to $10,000 maximum per ISF transaction. Per CBP-HQ: Since 7/9/13, any ISF not filed timely, accurately, and/or completely is in violation of ISF laws and at risk for claims. CBP s initial focus is a measured approach directed at egregious offenders (non-files, repeat late files, etc.). HQ reviews circumstances before port issues the 5955A. 13

14 Volume (per CBP as of 02/13/14) # Received By CBP-HQ: Over 200 requested by ports # Approved By CBP-HQ: 24, 20 have been issued for late ISF Types of Violations Late Files (all ISF claims to date issued for this reason) Inaccurate/Incomplete (98% of ISFs accepted) Missing B/L Missing bond information Duplicate ISFs B/L Mismatch ISF Enforcement - Liquidated Damages Makes ISF inaccurate Can also cause ISF to appear late due to mismatch 14

15 ISF Liquidated Damage Claims ISF Enforcement & 6-Year Statute Subject to 6-year statute per 28 USC 2415(a). Before 7/9/13: CBP has no intention of issuing any LD claims prior to when ISF enforcement began, except in cases of fraud. After 7/9/13: CBP has up to 6 years to issue an LD claim for any ISF violations that occur on or after 7/9/13. HQ Guidance to Ports in Q1 14 ISF enforcement should focus on most severe violations. Severe violations includes failure to file an ISF, significantly late ISFs, and repeat violations. Issue LD claims within 6 months or so of the ISF violation, otherwise understood no claim should be forthcoming. Does not remove CBP s right to issue claims up to 6 years per statute. 15

16 ISF Obligations and Updates Does the ISF obligation cease at the first ocean port of arrival? Are changes to the ISF allowed during transit or required after arrival at the port of discharge? Updates to the ISF are always allowed during transit and encouraged to reflect the most current information available. Per CBP s FAQ: Generally, the requirement to update an ISF terminates when the vessel calls at the U.S. port of arrival. However, CBP will not restrict updates outside of this window. Although importers are not required to file any ISF updates after the ISF obligation ceases at the first U.S. port of arrival, importers may do so if they prefer to do so for records to match in the event of an audit. The only exception to this is a Flexible Filing (FR, FT, FX) which must be updated to a Compliant Transaction (CT) at least 24 hours prior to arrival in the U.S. 16

17 ISF Compliance Best Practices Per CBP, always best to file ISF timely, update later CBP prefers that ISFs be amended or updated vs. deleted if changes to the ISF are required to make it accurate and complete. Update a timely ISF, don t delete and redo an untimely ISF. ISFs can be updated until cargo arrives in the U.S. 19 CFR 149.2(d) states the ISF must be updated if, after the filing is submitted and before the goods enter the limits of a port in the United States, any of the information submitted changes or more accurate information becomes available. CBP prefers updated information and ACE match at least 24 hours prior to cargo arrival for targeting purposes. A Flexible Filing (FR, FT, FX) must be updated 24 hours prior to cargo arrival as a Complete Transaction (CT). Failure to do so can result in a liquidated damage claim. CBP recommends fling as a Complete Transaction (CT) since updates can always be made. 17

18 Virginia Thompson Sr. Director of Import/Export Operations & Intl. Trade Compliance Euromarket Designs, Inc. 18

19 Who is Euromarket Designs? A leading home furnishings and furniture retailer operating under three brands 9,000 BOL s of U.S. Imports Countries of Origin 1,000 Active Vendors 19

20 How We Solved ISF Bid including NVOCC s, Brokers, Software Companies Landed on a Software Solution Leveraged other data/systems Self-filing 20

21 How It Works Vendor submits ASN no more than 3 days before sailing ASN Header provides: BOL Number Stuffer and Consolidator Mode of Transport P.O. s and SKU s in ASN provide all other data elements Classification Database ISF data is displayed in our ERP for review/correction User pushes ISF data to 3 rd -party software platform where it is automatically submitted to CBP 21

22 The Wins from Our Solution Self-filing Consistent, accurate data Will always match our entry/ftz admission data Cost-effective Less than $5 per ISF, including software and internal labor costs 22

23 Our Achilles Heel: Timeliness Dependency on 1,000 vendors to enter the ASN on time Last-minute loading Weekends/holidays U.S.-based vendors Don t know what s about to sail Efforts to address Late ASN penalty Moved from 75% to 90% compliance 23

24 The Solution to our Achilles Heel Visibility Software Solution EDI booking messages from carriers BOL # from the horse s mouth Shipment Plan separate from ASN Filtered view to see what s about to ship One goal of the project is 100% ISF timeliness 24

25 Impact of July 9 Enforcement CBP couldn t wait for us to go live Manual ISF Audit process Pre-sailing spreadsheets from carriers Cross-check with ISF data Follow-up with vendors Adding 1-2 hours per day Result: almost 100% timeliness 2-3 late ISF s since July 9, 2013 Still some with wrong BOL # s too 25

26 ISF After 5 Years: Wins Better visibility into supply chain at origin Better understanding of CFS and vendorloading operations Now we know who did the stuffing Shortages, overages, damage Overweight containers Forces us to classify SKU s earlier 26

27 ISF After 5 Years: Impacts Booking numbers must become BOL numbers Forwarders must file in ACE themselves Removed CFR from P.O. system as a Purchase Terms option Transportation & Financial teams need to update Compliance team on: Routing changes Sold-in-transit situations Unexpected SKU s on invoices 27

28 ABS Consulting Expertise Research Solutions Support Supply Chain Harmony Logistics and Trade Compliance Synchronized for Optimal Performance Albert Saphir Principal ABS Consulting 28

29 ISF Experience Today Major Clothing Manufacturer 5,000+ TEU annual container imports Originally an in-house system with high 90% performance Factory Garment Scan Carton Scan Packing List Data CHB CHB Add & ISF File ISF Approval to Factory Factory Packing List Print and Shipment Release Now outsourced using 3PL PO management system Should be easier and better but real life is more difficult than anticipated Time to resolve issues is now up to 4 hours from previously minutes 29

30 ISF Experience Today Major Clothing Manufacturer (continued) Biggest challenges early on and still today: AMS B/L match Number of origins Number of vendors Timeliness and accuracy (better before with in-house system) 3PL system removes factory involvement (less skin in game) Had a few HOLDS due to ISF timeliness and accuracy since commencement of CBP enforcement 30

31 ISF Experience Today Major Specialty Retailer 10,000+ TEU annual container imports 4,000+ customs entries Freight moves via NVOCC as well as direct VOCC contracts ISF filed by Customs Broker 31 31

32 ISF Experience Today Major Specialty Retailer (continued) Every day challenges: Spare parts (different ordering system) Accurate statistical performance reporting due to timing differences between broker, CBP and carrier systems VOCC filing errors (Simple B/L versus House B/L) Obtaining ISF visibility in broker system Timely presentation of vendor documentation (data) System limitations to unique/different scenarios Constant communication with vendors to ensure timely document submission (72 hours prior to cut-off) 32

33 ISF Experience Today Major Specialty Retailer (continued) Wins: Intensified partnership with customs broker to implement proactive compliance process Invalid SKU/HTS reporting monitored daily Dedicated ISF team reviews all upcoming filings daily Improved visibility of ISF process in broker system Monthly reporting maintaining a 99.5% on-time ISF filing average 33

34 Major Retailer Every day challenges: ISF Experience Today None really all working fine with an occasional minor error Wins: C-TPAT Tier 3 Self-filer for customs entries About 90% of entries, balance of customs entries are filed through one customs broker Not filing unified entries Using one forwarder/nvocc/consolidator to mange and coordinate all import shipments from all foreign vendors 34

35 Major Retailer (continued) Wins (continued): ISF Experience Today 100% of ISFs filed by foreign forwarder/consolidator directly to CBP No ISF data from supplier/shipper = no booking and thus no movement of freight ISF filed from first place of receipt/origin, even if cargo will be trans-shipped via feeder vessel Retailer retains control tower in US for daily monitoring of ISF Retailer reviews/audits ACE ISF reports on monthly basis 35

36 Lisa Gelsomino President/CEO 36

37 Financial Perspective Investment in ISF Compliance ISF Exposure for Importers Inventory costs based on 2-5 day shipment delays (cargo holds) Extra costs for holding freight at origin or destination if ISF missing/late Extra costs for non-intrusive inspection (NII) and/or full examination Range from $1,000 to $3,000 depending on port, storage time, etc. Liquidated Damage (LD) Exposure for ISF violations During measured enforcement period, CBP-HQ will review all ISF claims. Once this period ends, ports will have full authority to issue claims routinely as they do for other liquidated damage violations. 37

38 Liquidated Damage Costs ISF Exposure for Importers 100/Year % # Worst Best C-TPAT Average C1 Bond Violation% 3% 3 $ 15,000 $ 6,000 $ 3,000 $ 8,500 N/A Violation% 5% 5 $ 25,000 $ 11,000 $ 5,500 $ 16,000 N/A Violation% 10% 10 $ 50,000 $ 23,500 $ 11,750 $ 61,000 $ 50,000 Violation% 20% 20 $ 100,000 $ 48,500 $ 25,250 $ 73,500 $ 50, ISF transactions per year Violation Rate = % of ISF transactions with violations Worst assumes $5,000 liquidated damage per violation, no mitigation Best assumes $1,000 for 1 st time violation, $2,500 for all subsequent violations C-TPAT assumes 50% reduction of claims of best case scenario. Average assumes mix of best case and worst case scenarios. C1 Bond assumes the $50,000 minimum (about 92% of all bonds on file) 38

39 ISF Exposure for Importers Entry Process ISF Process Issue Outcome Issue Outcome Late-File LD = $100 Late-File LD = $5,000 Non-File LD = # days late Non-File LD = $5,000 Incomplete/Inaccurate Corrected Entry Incomplete/Inaccurate LD = $5,000 Mitigation OIC or Petition Mitigation Only Petition/No OIC Liquidation One Year Liquidation ISFs don t liquidate Statute of Limitations 6 Years Statute of Limitations 6 Years Entries: Bonds written guarantee future obligation to pay duty and comply with laws ISF: Right of action occurs 24 hours prior to vessel departure (timely/accurate/complete) If ISF is late, this results in need for an ISF Bond with known violations and claims Insurers don t insure after a loss occurs (i.e. provide flood insurance while flooded). Sureties don t want to write bonds for known claims either, but will do so with collateral. Bonds are not Insurance 39

40 CBP requires ISF bonding per CBP 19CFR149(b) & 19CFR113-G Activity Code 1 Importer/Entry Bond is primary bond Bond guarantees importer s compliance with laws and regulations Liquidated Damages result from breach of the surety contract ISF $5,000 per any one violation; $10,000 maximum per transaction Parties to a Customs Bond Contract Customs Bond Contract Sureties obligate ISF importer s performance to comply with laws; can subrogate against importer to be made whole. 40

41 ISF Claim Examples (Avalon Data) Departure Date ISF Filed Date/ Violation Date # of Days Late Date of Cargo Arrival in USA ISF Progress Report Status 7/12/2013 7/17/ /31/2013 Not Available Petition Granted Reduced to $1,000 7/12/2013 7/24/ /29/2013 Not Available Petition Pending 7/12/2013 7/29/ /31/2013 Not Available Petition Pending 7/12/2013 7/30/ /29/2013 Not Available Petition Pending 7/12/2013 7/18/ /31/ % ISFs Late 5/1/13-7/31/13 Petition Granted reduced to $500 7/22/2013 7/24/ /28/2013 Not Available Petition Granted reduced to $500 None of these claims had an NII or exam prior to issuing claim. Only one of the claims had an ISF hold and subsequent LD claim issued. An LD claim can be issued even if there is no ISF cargo hold and/or NII or exam. 41

42 ISF Mitigation Guidelines Violation Type Cause Max. 1 st Violation All Other C-TPAT ISF-10 Filing Late File $5,000 $1,000-$2,000 $2,500 50% ISF-10 Filing Inaccurate Filing $5,000 $1,000-$2,000 $2,500 50% ISF-10 Filing Inaccurate Update(s) $5,000 $1,000-$2,000 $2,500 50% ISF-10 Filing Withdrawal/Deletion $5,000 $1,000-$2,000 $2,500 50% Mitigating Factors ISF-5 for FROB cargo is not subject to liquidated damages at this time, but would be subject to same violation types and mitigating factors. 6 Mitigating Factors: 1) ISF progress since 1/26/09; 2) Small # of violations to shipments (as %); 3) C-TPAT Tier 2 or 3 status; 4) Demonstrated action to reduce future violations; 5/6) ISF filed late or inaccurate, can mitigate if due to factors outside importer s control (such as carrier error). 4 Aggravating Factors: 1) Non-cooperative; 2) Multiple errors on the ISF; 3) Rising/Deteriorating Error Rate; 4) Smuggling/Fraud. 42

43 ISF Mitigation Best Practices Describe Nature of Error or Violation If clerical in nature, describe why violation occurred If ISF Filer or Carrier at fault, provide specifics Was it a one-time or repeat error? Explain Outline how future violations will be avoided Importer s ISF Performance Record How long has importer been compliant with ISF? Emphasize importer s compliance record Timeliness and Accuracy Percentages (i.e. 95% timely/98% accurate) Include ISF Progress Report (your report or from ACE portal) Overall cooperation 43

44 ISF Mitigation Best Practices C-TPAT Reduction (50%) When submitting petition, advise CBP if the ISF importer and the ISF filer are C-TPAT certified to obtain best mitigation. CBP may consider 50% mitigation if the ISF Filer is C-TPAT certified and/or contributed to the violation. CBP should not be requesting a copy of the C-TPAT certificate as proof, this can be verified by CBP if stated in your petition. Also visit: certified-participants 44

45 ISF Progress Reports ACE ISF Portal CSMS # effective 7/13/11 Importers and ISF Filers have access to ISF Report Cards in ACE Previously only available through monthly subscription Questions on ISF Progress Reports to Reports also available to Importers, ISF Filers, and Sureties (limited data) Data provided in varying formats, to surety only as a monthly data download Importers with 12 or fewer ISFs per year Can file directly through ACE portal Importer would need continuous bond, ISF-D single not available in ACE portal Reports Generated Monthly (for prior month s activity) Importers, ISF Filers and Sureties are all posted on different days If not posted by 10 th of the month, contact ACE Help Desk 45

46 ACE ISF Portal All ACE accounts access ISF reports in same manner Go to References Tab Select Task Links from Menu Panel on the left Button to Launch ISF will appear Launch ISF will open new window Sign up for reports in Reports Menu Reports will then appear in Reports Tab (check daily) 46

47 ISF Progress Reports Per CBP, only an estimate of ISF compliance C-TPAT tier 2 and 3 receive line item detail 47

48 ISF Progress Reports Measures ISF Timeliness based on Vessel Departure Messages (VDMs) received by CBP minus 24 hours per local time. ISFs Not Measured for Timeliness occur when no VDM was received by CBP. Per CBP, these are not late ISFs and do not negatively affect an importer s compliance rate. 48

49 ISF Surety Data in ACE Surety receives snapshot of ISF activity (monthly) Surety not receiving vessel departure message/date ISF ISF Imp Filer Filer Imp # Name Name ISF Sent Date Format Action Status Action Shipment Reason Type ISF Status ISF Transaction Count based on Avalon Data Based on data sureties began to receive through portal as of July 2011 Format/Filer: 80% ABI; 20% AMS Status: 99.89% Accepted;.11% Rejected Action Reason: 98.28% Compliant Transaction vs. Flexible Filing (FR, FT, FX) Bill Type: 68% House B/Ls; 32% Ocean/Regular B/Ls Bond Type: 98.4% CBs; 1.6% STBs ISF# SCAC Bill# Bill Type Bond Type Bond Code Error CTB Bond # STB Bond Ref # 09/06/11 01:38:24 PM ABI Add Active CT 01 Accepted BM 9 16 STB# 09/13/11 04:19:38 PM AMS Add Active CT 01 Accepted OB 8 1 CTB# 49

50 In Conclusion Exposures for ISF Importer of Record ISF importer responsible for timely, complete, accurate ISF. ISF importer responsible for cargo holds and/or liquidated damages. ISF importer also subject to penalties under 19 U.S.C. 1595a(b) = value of cargo, reserved for fraudulent violations or absence of bond obligation. C-TPAT importers receive benefit from best practices and 50% mitigation. Exposure for ISF Filers (CHB or OTi) Per CBP regulations, the ISF importer is responsible for all ISF activity and enforcement as referenced above. National Customs Brokers & Forwarders Association of America (NCBFAA) Terms & Conditions of Service limit liability to $50 per Entry/ISF. E&O insurance 50

51 Questions? Thank you for participating today! 51

52 Contact Information Albert Saphir, Principal ABS Consulting Today s ISF panel is presented and moderated by Albert Saphir Over 30 years in international transportation and trade compliance T: / E: albert@abs-consulting.net M. Craig Clark, Program Manager, Office of Cargo and Conveyance National point of contact for all ISF matters at CBP Headquarters in DC T: / E: craig.clark@cbp.dhs.gov Refer to CBP ISF website for current information Lisa Gelsomino, President/CEO Avalon Risk Management Leading provider of Customs and ISF Bonds; NCBFAA ISF Sub-committee w/ CBP ISF outreach to 2,000+ trade members, see T: / E: lgelsomino@avalonrisk.com Virginia Thompson, Senior Director of Import/Export Operations and International Trade Compliance Crate & Barrel ISF compliance from an importer perspective for one of the largest retailers T: / E: vthompson@crateandbarrel.com 52