Increase in C-TPAT Enforcement — and Enforcement Costs
As C-TPAT has matured, Customs and Border Protection’s emphasis on compliance is sensible, and CBP is to be commended for ensuring that the program is a real security program and not merely a “paper program.” But CBP also must be careful to ensure that suspension and revocation decisions are made consistently across C-TPAT membership and that decisions are made in a timely way and in accordance with transparent procedures. There is anecdotal information that consistency and transparency are not yet hallmarks of CBP’s compliance efforts.