CBP Has Issued 1,300 Penalties for EEI Filings in Last 6 Months
On June 10, 2010, U.S. Customs and Border Protection held a webinar on outbound issues as part of its series of trade outreach events. Highlights of information presented at CBP’s webinar include:
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Approx 1,300 EEI Penalties Issued in Last 6 Months
CBP officials discussed the Foreign Trade Regulations (FTR), noting that CBP has been delegated the authority to issue penalties to violators. According to CBP officials, during the last six months, CBP has issued approximately 1,300 penalties for Electronic Export Information (EEI) filing violations.
CBP officials discussed CBP’s mitigation guidelines for violations of the mandatory AES filing requirements and other Foreign Trade Regulations. These guidelines were effective February 1, 2009, for violations occurring on/after February 1, 2009.
(See ITT’s Online Archives or 01/30/09 news, 09013025, for BP reminder on these guidelines.)
CBP Discusses Common Errors in Export Reporting
During its discussion on enforcement, CBP officials listed some of the most common errors and violations they see, including:
- 15 CFR 30.6 (Electronic Export Information data elements) -- problems such as incorrect port of export, etc.
- 15 CFR 30.4 (EEI filing procedures and deadlines) -- problems such as the EEI not being timely filed, etc.
- 15 CFR 30.47(b) -- (Clearance or departure of carriers under bond on incomplete manifest) -- problems such as a carrier failing to file all of the required certifications, exclusions, exemption legends, etc.
- 15 CFR 30.2 (General requirements) -- problems such as an incorrect date of departure, incorrect values (e.g., value under-declared), no carrier or incorrect carrier information, incorrect Schedule B number, etc.
CBP Working on Automated Systems, Export Control Reform, Etc.
CBP officials stated that the projects they are focusing on in the outbound area include:
Automated systems. CBP is looking at its automated systems, both for the short-term (Automated Export System) and long-term (Automated Commercial Environment export module).
Regulatory reform. CBP is playing a role in the President’s Export Control Reform Initiative.
Improving facilities. CBP is working to improve facilities that will handle and process exports, travelers, conveyances.
Staffing. CBP is working on its budget to increase staffing, specifically staff that is dedicated to the outbound process for cargo, travelers, and conveyances.
Best Practices for Export Compliance
CBP officials also discussed “best practices” for export control, including:
- AES transmission and export documentation should match each other
- If a party receives a request from CBP officer for more information or a penalty notice from FP&F, the party should respond as soon as possible. CBP also suggests correcting problems as quickly as possible.
- Voluntary disclosures -- especially on cargo that was not properly exported
- Be aware of the Census regulations -- violations can sometimes be technical
(See ITT’s Online Archives or 05/06/10 news, 10050648, for previous BP summary announcing this webinar.)