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Coppersmith Global Logistics has been actively preparing a suite of options to meet your expectations for submitting your Importer Security Filing on January 26, 2009.

Please read on to obtain the latest updates and to sign up for our webinar introducing our exciting web based system.

IMPORTER SECURITY FILING

Effective Date: The Interim Final Rule will take effect on January 26, 2009

Compliance Date: 12 month delayed compliance period from the effective date to allow industry to comply with the new requirements is January 26, 2010. The 12 month delayed compliance period may be extended if circumstances warrant.

REVIEW PERIOD

• During the first year, CBP will monitor all ISF submissions for timeliness, accuracy and completeness and will work with any non-complying ISF filer in order to help them adhere to the new requirements
• CBP will consider an entity's progress in the implementation of the rule during the delayed enforcement period as a mitigating factor in any enforcement action following the delayed enforcement period
• On the basis of information obtained during the structured review and public comments, DHS will undertake an analysis of the elements subject to flexibilities added to the Interim Final Rule
• DHS, in coordination with other parts of the Executive Branch, will determine whether to eliminate, modify, or leave unchanged these requirements
• This only applies to the flexible requirements

FLEXIBLE ENFORCEMENT
In order to provide the trade sufficient time to adjust to the new requirements and in consideration of the business process changes that may be necessary to achieve full compliance, CBP will show restraint in enforcing the rule, taking into account difficulties that importers may face in complying with the rule, so long as:

• Importers are making satisfactory progress toward compliance and
• are making a good faith effort to comply with the rule to the extent of their current ability
• This policy will last for twelve months after the effective date and will apply to all aspects of the filing rule
• CBP is committed to fully supporting the trade community in its efforts to successfully implement the requirements of this rule

ENFORCEMENT OPTIONS

• CBP will enforce the Importer Security Filing, requirements through the assessment of liquidated damages, in addition to penalties applicable under other provisions of law.
• However, during the Structured Review and Flexible Enforcement Period will not:
1. issue liquidated damages for failure to comply with the "10+2" requirements
2. use the do not load (DNL) hold function for failure to comply with the "10+2" requirements (i.e. timely, accurate and complete filings)

• This period will be for a minimum of one year and will commence from the effective date
• If circumstances warrant, CBP reserves the right to take any and all actions required to protect the security of the United States

COPPERSMITH OFFERS 3 OPTIONS FOR FILING YOUR ISF

1. Coppersmith Website

1. Apply for a Login & Password
2. Enter data elements
3. $20 per transmission

2. Excel Spreadsheet

1. Have your IT people speak to our IT people
2. Upload to Coppersmith
3. $20 per transmission

3. Give us manual data

1. E-mail or fax ISF worksheet, invoices, B/L, other
2. We key it in and obtain ISF confirmation number
3. $50-$85 per tranmission depending on total number of HTS lines manufactures and countries of origin