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While we are in the enforcement phase it should be noted that the approach taken by CBP is labeled “Graduated/Escalated”. In essence, CBP will show restraint in issuing penalties as the trade continues to work through the barriers associated with ascertaining information in a timely manner. It is important to note that CBP expects the ISF to be filed irrespective of whether it is complete and or accurate.
It is imperative for importers to be communicating with their suppliers so as to receive the required information timely. We have the software and procedures in place to accommodate the ISF and assist in managing the program to ensure you are in compliance.

