Increased ISF Enforcement on the Horizon

Dear Friends:

Just a quick note to let you know that US Customs and Border Protection recently announced that it is “making preparations to enter into the liquidated damages phase of the Importer Security Filing (ISF) enforcement process.” 

In a June 7, 2013 posting to its website, CBP announced that it will begin assessing liquidated damages for ISF violations as of July 9, 2013.  Liquidated damages of up to $5,000 per violation will be assessed for incomplete, inaccurate or untimely filings.  Also, if the ISF has not been filed at the time of arrival, CBP can (in addition to imposing penalties) withhold the release or transfer of the cargo.  CBP’s posting can be found here.

Given that ISF has been in effect since January 2009, importers should expect CBP to be pretty aggressive in pursuing violations and imposing liquidated damages beginning July 9, 2013.  Accordingly, if your ISF program needs a tune-up, now is the time to do it.

If you have any questions, or if you would like to discuss ISF further, please let us know.

Best regards,



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