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Skip Navigation Links Home > TRG Spotlight Archives > Trade Spotlight July 2009
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Importer Security Filing Mitigation Guidelines

We are nearing the 11th hour of Importer Security Filing. The mitigation guidelines were published in Customs Bulletin & Decisions on July 17th. At this time, reality is setting for many importers who have not prepared for this very serious regulation with stiff monetary penalties.

6 Months Down 6 More To Go

Rich DiNucci, Director, Secure Freight Initiative, recently presented statistics on the industry’s compliance over the first six months of the ISF implementation phase. Customs and Border Protection has received 1.4 million ISFs from 57,000 importers. Of these filings 46% have been timely. Is your company one of the 57,000? If so, keep it up, CBP will recognize your effort and you will be rewarded. If not, call TRG Direct today and we can get set you up with an ISF direct filing program within days. Face the facts, your progress during this probationary period will be a factor next January when fines/penalties come into play.

ISF Liquidated Damages

Four factors that may cause a loss of integrity in the ISF may result in liquidated damages. These include: failure to submit, late submission, failure to update or failure to withdraw. Penalties per ISF will be assessed at $5,000 up to $10,000. The first and second violations made by the company may be forgiven for less than the $5,000 penalty.

6 Mitigation Factors

Six mitigation factors will be used to determine the strength of the liquidated damages and whether or not the penalties are dismissed.

1. Progress of the importer’s ISF program,
2. Percentage of ISFs containing violations,
3. Tier 2 & 3 C-TPAT members will receive consideration up to 50 percent,
4. Action taken by the importer after a violation has occurred,
5. Circumstances beyond the importer’s control,
6. Inaccurate information received by another party within the supply chain.

It's Not Too Late. Your ISF Solution is here.

Become a direct filing partner with TRG Direct and take control of your ISF. We can get you up and filing within days and help guide you through this new regulation. Let us help you develop a successful direct filing program and prove to CBP that you are committed to compliance. Not only is TRG Direct the most user friendly system available, but you can file your ISF for only $3 - $5.

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Trade Risk Guaranty (TRG) Brokerage Services LLC is a licensed insurance agency, having agency agreements with Hanover  Insurance Company of Worcester, Massachusetts and Great American Insurance Company of Cincinnati, Ohio, both of which are insurance companies approved by the Department of the U.S. Treasury to issue U.S. Customs bonds.

Our marine policies are written by our sister agency, Corporation for International Business – dba Boomerang Freight Solutions Insurance Agency in the state of CA, dba Corporation for International Business, Inc. in the states of CT/MA/MO/NM, and dba CIB Insurance Agency, Inc. in the states of FL/MD/NH.