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Nov. 16, 2010

Leigh A. SchmidSenior Vice President

Limited BrandsGlobal Trade Compliance

216

AutomationRecently conducted a survey on ACE

Working with Cynthia Allen the new Executive Director, ACE Business Office

AgricultureWorking on pest control programs such as Asia Gypsy MothWorking on a survey that will be distributed to the trade.

Air Cargo Security Working with TSA and CBP to eliminate redundancies and improve efficiency on security programs (e.g. credentialing, security checks, etc.)

BondsProviding advice on the effects of Bond Centralization. Commenting on Notice of Proposed Rulemaking (NPRM) which amends 19CFR 113 (the bond regulations).Providing feedback on CBP’s updated Bond Directive(s).

COAC Subcommittees (11th Term)

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217

Global Supply Chain Securityprovide feedback on the Administration’s efforts to develop a National Strategy for Global Supply Chain Security

Intellectual Property Rights EnforcementRecommended the new Continuous Bond allowing CBP to provide samples of products to rights holders for review.Working on a Prior Disclosure process for IPR violations

Importer Security FilingWorking with CBP on ISF implementation. Current issues include the “finalization” of an ISF filing (when is a filing complete?).

Trade FacilitationWorking on several trade facilitation efforts including “Management by Account”, “Centers of Excellence”, etc.

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COAC Subcommittees (11th Term)

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Management By Account

219

Spectrum of Traders

Unknown

• Intervene to ascertain risk level

• Build Compliance or Stop

High Risk Generally Compliant

Trusted Most Trusted

• Enforce

• Discourage

• Gain Compliance or Stop

• Less interaction

• Trust, but verify

• Account Manager

• Facilitation

• Account Executive Team

• “Gold Key”

Unknown

• Intervene to ascertain risk level

• Build Compliance or Stop

High Risk Generally Compliant

Trusted Most Trusted

• Enforce

• Discourage

• Gain Compliance or Stop

• Less interaction

• Trust, but verify

• Account Manager

• Facilitation

• Account Executive Team

• “Gold Key”

Bulk of CBP Resources Bulk of IncentivesBulk of CBP Resources Bulk of Incentives

Transactional Interaction Account InteractionTransactional Interaction Account Interaction

220

Reduce volume and redundancy of data transmissions

Reduce post entry queries and amendments

Enable statement-based processing for entry summaries and payments

Enable CBP to focus resources on higher risks

Simplified Entry Processing Goals

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221

Participation by ISA trusted partners

Entry summary for single importer of record based on common data elements

Proposed due date – ten days after the last release in the specified time period (supported by Census)

Each line would represent shipments released in the period with common data elements (Harmonized Tariff Schedule (HTS), country of origin, manufacturer, surety, etc)

No change to entry summary data elements currently required

Periodic Entry Summary Concepts

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222

CSA program simplifies the entire border crossing process for low-risk, pre-approved companies.

Importer, carrier and driver go through an application(s) and risk assessment process with CBSA prior to approval.

Once qualified, no advance data required.

For truck mode, the driver presents three pieces of information: Carrier Code, Importer Business Number and the Driver FAST or CDRP Card. (3 Bar Codes)

All three pieces of information are scanned and a risk assessment completed by a targeting system. Once approved the delivery is authorized.

Closely Examined Canada’s “Customs Self Assessment” (CSA) Program§

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223

Liability for duties and taxes remains with the CSA Carrier until the shipment is delivered to the CSA Importer.

Date of delivery is the “deemed” date of release for the importer.

The Importer pays duty on a periodic (monthly) basis according to the release date.

The “Revenue Summary Form” (RSF) lists all duties and taxes owing, and all adjustments to previous reports including refunds, drawbacks, voluntary tenders, etc.

The RSF is an electronic (paperless) filing.

Canada’s “Customs Self Assessment” (CSA) Program§

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224

Serve as a central point of contact for trade partners in the industry sector

Create an engagement plan with trusted partner to gauge compliance while minimizing touch points

Described as a “National Account Manager on steroids”.

Leon Hayward, Assistant Director, Field Ops, Trade and Cargo Security in NYC is the pilot Account Executive for the electronics industry.

Pilot started Nov. 1st

Account Executive Functions

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225

Exploration of a Center of Expertise (CoE) concept of operation was initiated by the COAC

Goal of this industry-focused sub-organization will:interweave “Management By Account” throughout its operational and decision-making processes; promote trade collaboration to achieve greater transparency;recognize trusted partner commitments; andembrace the overall trade strategy

CBP will consolidate industry expertise to provide uniform treatment in the application of the law, regulations, processes, and procedures, and manage risk

Center of Expertise Purpose

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226

Implement a finite life span for non-trusted partners and exploit a fluid pool of account candidates based on risk

Engage and manage entities regardless of size, value or volume

Collect and analyze information to identify areas of risk

Lead activities and develop comprehensive strategies to manage risk

Initiate and carry out compliance and enforcement actions

Track and report performance results

Risk-Based Account Management§

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227

National Account ManagersEntry Specialists

Import SpecialistsProgram Managers

Paralegal SpecialistsDrawback Specialists

HeadquartersCBP Officers

CBP AttorneysRegulatory Auditors

National Import SpecialistsInternational Trade Specialists

Supply Chain Security SpecialistsNational Targeting Analysis Group

Laboratories and Scientific ServicesCommercial Targeting and Analysis Center

Industry

PortsNAM

HQ

NTAGCTAC

C-TPATLSS

Collaboration

RegulatoryRegulatoryAudit

RegulationsRegulations& Rulings

228

Commissioner’s letter dated Oct. 21, 2010 announced a slight name change to Centers of Excellence & Expertise (“CEE”)

Pilot to develop comprehensive strategies to facilitate trade and manage risk in the pharmaceutical industry began on Nov. 1st.

Anne Maracich, Asst. Port Director, Los Angeles International will direct the pilot center.

Authority extends to advice and coordinating activities that impact port operations.

CoE (now CEE) Pilot

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