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C-TPAT represents the Customs-Trade Against Terrorism (C-TPAT) partnership. This program is a joint government-business initiative to establish cooperative relationships that strengthen the entire supply chain and border security, while recognizing that Customs can only provide maximum security in close cooperation with its industrial partners. The documents describing the C-TPAT initiative clearly show that their roots are the Sea Carrier Initiative Agreement (SCIA) and the Business Anti-Smuggling Coalition (BASC) program. In addition to meeting the approval criteria, a sea carrier must also meet the “minimum safety criteria – sea carrier”, the latest version of which dates from November 2019 (see annex). BIMCO, however, views the 24-hour manifest rule with some skepticism, as BIMCO questions the ability of U.S. Customs to analyze and report to the carrier within the set 24-hour period. BIMCO also believes that the 24-hour rule is currently not feasible for bulk goods. To be eligible for CTPAT certification, a BIMCO carrier must have taken the initiative to develop the text of a clause as quickly as possible that takes into account potential liability for the costs of sending security personnel to U.S. ports.

The fact that unlicserved shipowners in the United States (usually smaller shipowners) are prevented from enjoying the benefits of CTPAT is a problem for BIMCO. In the future, BIMCO will strive to develop a solution for officeless businesses in the United States, which will reward active participation in the fight against drug trafficking. The development of such a program – a light CTPAT, if you prefer – depends on CBP`s willingness to listen to and adapt its current concepts, and also requires that additional resources within CBP be used to fund such new initiatives. While this may prove difficult in the short term, I hope that the benefits to the security situation in the United States will justify the need to allocate CBP funds, but time will show it. The BIMCO secretariat will report to members as soon as possible on developments. Asked about the outcome of the meeting with the Immigration and Naturalization Service (INS) Herr. . . .