I just attended the BIS Update Conference in Washington last week. The conference is totally export focussed and speaker after speaker emphasized the collaboration and cooperation of export regulations and enforcement across Departments of Commerce (BIS), State, Defence, and Treasury (OFAC). This new export compliance regime is the culmination of policy enunciated by President Obama in 2009 and made executable through executive order. This cooperation amongst export focused government agencies was, and is, a massive undertaking and it will indeed make life simpler, in many respects, for the exporter.The inter-agency collaboration initiative was not solely export focused. It is part of a much larger initiative that requires that all government agencies that had anything to do with trade get together and design and implement a unified solution. From an import perspective it is called ACE "Single Window".What does this mean for companies involved in international trade. The bottom line is it simplifies the way you can interface and communicate with CBP and all Partner Government Agencies (PGAs). It provides you with much more direct access to information stored and managed within the ACE environment. It centralizes areas of expertise according to your industries in CEEs (Centers of Excellence and Expertise). This allows the importer or exporter access to a central resource to discuss issues and appeal the arbitrariness that has, and can occur at the different ports of entry (POE) with different interpretations of classification by CBP and PGA officers. It allows for importers and exporters to directly file entries and security filings with the appropriate agencies through a singular submission, if they heel so inclined.By the way, as an importer you are automatically enrolled in a CEE, even if you don't know it. It is really worth checking out and building your relationship.All really good stuff along the road to simplifying the way the exporter or importer interfaces with the appropriate government agencies.However, there is a significant opportunity for downside to the importer and exporter for all this centralization. There is no disputing the fact that for many importers and exporters life will be simpler and more efficient through the centralized ACE environment. So what is the downside.The bottom line -CBP and PGAs now have greater visibility over your behaviour as an importer or exporter. They are collecting information at an unprecedented rate and are developing the ability to analyze the data and create a singular profile that is shared across agencies. Inaccuracies, whether intentional or not are all made evident.This means that those companies that are able to meet CBP and PGA filing requirements completely, accurately and in a timely manner will have less friction at the point of entry. Those companies that can't or don't file accurately will find that their products are held more frequently at ports and that there will be greater subsequent interest by CBP in the way the company manages and controls their customs related processes.There is a move by Customs to re-balance the emphasis between security and tariff enforcement. The creation of the single window is a major step to enabling CBP and PGAs to get the information they need to better enforce the rules and regulations pertaining to the movement of goods and services through the border.With the election of Donald Trump there are a lot of questions as to how his particular orientation will impact global trade vis a vis the United States. One can only suspect that the enforcement of the tariff regime at the border will only intensify under a Trump administration, making life for the importer and exporter more onerous.Having systems in place to ensure that your organization can meet the current and future requirements of CBP and PGAs is not only good practice. This is now becoming more of an imperative as ACE Single Window is the new reality.
About 3rdwave:
3rdwave simplifies global trade through automation. 3rdwave is a GTM platform that minimizes manual data entry, streamlines business process, and provides contextual information enabling its users to make informed decisions to reduce global supply chain risk. It's a cloud-based platform, resulting in minimal IT resources for quick implementation. 3rdwave ensures that companies meet the highest levels of GTM execution and Trade Compliance conformance.
Ned Blinick is Chief Product Officer of 3rdwave.co. He has been involved in global trade for too many decades and he loves making the global supply chain simpler for everyone. If you would like to engage with Ned he would really enjoy the opportunity of communicating with you or your boss. He can be reached at (416) 510 8800 ext 234 or at eblinick@3rdwave.co
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