CB8u—Intro to U.S. Customs Brokerage, Part 8: Post-Entry Summary Filing Operations and CBP Enforcement

Subscriber price: $109.00, Non-subscriber price: $141.00
Estimated total study time: 7 hours 31 minutes

This is the eighth of the nine-part series of introductory courses in the practical work of U.S. customs brokerage. This course provides a basic understanding of the requirements for entry transmittal in the Automated Broker Interface (ABI) and operational sequence to get ready for inputting the entry information. Then we address operational and customs requirements post entry to include re-forwarding, liquidation of the entry, accounting including billing the customer, and recordkeeping. U.S. import violations and enforcement measures will also be covered to reiterate the administrative and criminal sanctions that can result from import violations and the ability the broker has to help thwart terrorism, smuggling and fraud.

Important: This course can be taken out of sequence if so desired.

ABI Entry Filing Procedure and Operational Sequence

In this lesson we will illustrate the general sequence of events for filing your entry via ABI, what CBP selectivity processing is and how it is used, and the time limitations involved. Proper organization of the paper entry documents is also important for customs submission and record keeping.

(Estimated study time: 1 hour 31 minutes)

Introduction
ABI Entry Filing Procedure & Operational Sequence
- General Sequence of Events
  - Overview of Entry Filing Process
  - Release With Full Entry Summary Data Transmitted
  - Release Without Full Entry Summary Data
- Customs Selectivity Processing
  - What is Cargo Selectivity?
  - When Does Selectivity Processing Occur?
- Time Limits for ABI Transmission of Customs Release and Entry Information
  - General Timeframes — Shipment Data Transmission & Filer Release Certification
  - Other Agency Time Requirements
  - Transmitting Corrections and Updates
- Audits, Warnings and Fatal Errors After Transmitting the Entry through the Automated Broker Interface
  - Bureau of Census Import Parameters
  - Automated Broker Interface Warnings and Rejects
Organization of Paper Entry Documents for Customs Submission and/or Record Keeping
- Step 1: Document Review
- Step 2: Logging File in System for Tracking
- Step 3: Verify Customer and Determine Importer of Record
- Step 4: Call for Additional Information as Required
- Step 5: Validate Freight Charges
- Step 6: Purchase Documents as Necessary
- Step 7: Perform Data Entry and Invoice Rating
- Step 8: Surrender Bill of Lading and Collect Freight Charges as Necessary
- Step 9: Complete Customer Billing
- Step 10: Print and Assemble Documents
- Step 11: Document Submission and Release Monitoring
- Step 12: Monitor for Proof of Delivery as Necessary

Processing Import Requirements Imposed by Other Government Agencies

Import requirements imposed by other government agencies can be complex. Only a few of these agencies use electronic messages to enforce their requirements. Sometimes there are hard copy document requirements. In this lesson we will cover these other agency requirements.

(Estimated study time: 45 minutes)

Introduction
U.S. Import Data Communication with Partner and Other Government Agencies
- Additional Government Agency Submission for Cargo Release
- Partner Government Agencies with Electronic Filing Capabilities
- Example Data that Triggers PGA Flags in ACE

Additional Requirements for Entry Summary Transmittal

This lesson covers the customs power of attorney is required for an agent to perform customs business on behalf of an importer. We also briefly cover payments to vendors other than CBP.

(Estimated study time: 38 minutes)

Introduction
Importer Authorization to Act as Agent
Ultimate Consignee at the Time of Release and Entry Summary

Payment of Duties and Fees

ABI brokers are required to submit all entries through ABI. For this reason, ABI filers can pay multiple entry summaries with one check or Automated Clearing House payment. In this lesson we will cover the types of statements and methods of payment.

(Estimated study time: 1 hour 5 minutes)

Introduction
Payment of Duties and Fees
- ABI Statement Processing
- Duty Payment by ACH
- Duty Payment by Check
- Submission without Duty Payment

Operational and Customs Requirements Post Entry

What happens after the entry is filed? In this lesson we cover the delivery of goods to the importer, also known as re-forwarding, liquidation of the entry, accounting, including billing your customer, and record keeping.

(Estimated study time: 1 hour 20 minutes)

Introduction
Operational and Customs Requirements Following Entry (Release) of Goods
- Delivery of Goods to Importer ("Re-Forwarding")
- Entry Summary for Formal Entries
- Accounting
  - Customs Broker Accounting Requirements
  - Payment Terms
  - Credit Limits
  - Vendor Account Payables
    - Methods of Payment
  - Accounts Receivable from Customers
  - Accounting for Disbursement Made on Behalf of Importer
    - Disbursements Made Prior to Invoicing Importer ("Advances")
    - Disbursements Made after Invoicing Importer
  - Customer Invoicing
Recordkeeping Requirements and Procedures
- Parties Required to Keep Records
- Record Retention Period
- U.S. Customs Broker Records
  - Customs Broker Records Storage
  - Customs Broker Records Maintenance
  - Customs Broker Records Retrieval
  - Customs Broker Destruction of Records
  - Customs Broker Records Security
  - Customs Broker's Confidentiality of Records

Post Entry Remedies for Error Correction and Entry Finalization

This lesson gives a short overview of the work involved in correcting entries that were not done right the first time. It also stresses the importance of reporting and correcting any errors that may be discovered.

(Estimated study time: 1 hour 26 minutes)

Introduction
Post Entry Remedies for Error Correction and Entry Finalization
- Post Entry Requests Initiated by CBP
  - CBP Form 28 Request for Information
  - CBP Form 29 Notice of Action
  - CBP Form 4647 Notice to Mark/Notice to Redeliver
  - Post Summary Request for Documents
- Liquidation and Finalization of the Entry Summary
- Methods of Reporting a Change to Entry Summary Information
  - Post Summary Correction (PSC) in Automated Commercial Environment (ACE)
  - Protest CBP Form 19
  - Four types of Administrative Review
    - Authority to Voluntarily Reliquidate (19 USC 1501(a))
    - 19 USC 1520(a)(4) Administrative Refund
    - 19 USC 1520(c) Clerical Error, Mistake of Fact, Other Inadvertence
    - Goods Qualifying under Free Trade Agreement Rules of Origin 19 USC 1520(d)
  - Petitions and Supplemental Petitions for Relief of Liquidated Damages
    - Mitigation or Cancellation of Claims for Liquidated Damages
    - Offer in Compromise
  - U.S. Customs Reconciliation Entry Program
  - Prior Disclosure of a Violation
  - Duty Drawback Claims

U.S. Import Violations, and Enforcement Measures

CBP requires that customs brokers help in the effort to thwart terrorism, smuggling, and fraud. Here we discuss how Customs brokers are scrutinized, the types of import violations that occur and the possible administrative and criminal sanctions that can result.

(Estimated study time: 47 minutes)

Introduction
General — CBP Scrutiny of Customs Brokers
Types of Import Violations
- Smuggling
- Fraudulent Documents and Declarations
  - Documents Fraudulent from the Outset
  - Altered Documents
- Trade Facilitation and Trade Enforcement
  - Trade Facilitation and Trade Enforcement Act of 2015
  - Forced Labor Investigations
  - Investigation of Antidumping or Countervailing Duty Evasion
  - Enforcement of Intellectual Property Rights
- CBP Enforcement of Other Government Agency Regulations
CBP Administrative and Criminal Sanctions
- Administrative Sanctions
- Criminal Sanctions