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Updated Security Criteria for CTPAT to be Phased in Starting in 2019

U.S. Customs and Border Protection is currently circulating within the trade community draft modifications to the minimum security criteria associated with the Customs Trade Partnership Against Terrorism. CBP is gathering input on the proposed changes through the end of October and plans to implement the final updated MSC under a phased approach throughout fiscal year 2019.

CBP states that this is the first major revision of the MSC since the inception of CTPAT and is designed to modernise and strengthen requirements to more effectively combat evolving supply chain security threats such as the exponential increase in the volume and complexity of trade, the heightened risk of data breaches and cyberattacks, and the continued targeting of global supply chains by terrorists and criminal organisations. Generally, the changes include establishing three focus areas and three new criteria categories, explicitly delineating requirements as “must” or “should” based on risk, and providing guidance on how to combat terrorism financing and money laundering.

An overview of the updated MSC is provided in the following chart.

Focus AreaMSC CategoriesDescription
Corporate securitySecurity vision and responsibility (new)Promote a security vision, integrate security throughout the organisation, establish an audit process, importance and role of the CTPAT point of contact
Risk assessmentComplete a comprehensive risk assessment based on a recognised methodology and in line with the MSC
Business partner requirementsSelect, screen and monitor business partner compliance with MSC, including trade-based money laundering
Cybersecurity (new)Written cybersecurity policies and procedures, protection of IT systems with software and hardware, remote access, personal devices
Transportation securityConveyance and IIT securityConduct thorough inspections for both security and visible agricultural contamination, driver verification, tracking of conveyances, random searches
Seal securityHigh security seal policy, containers not suitable for sealing, mandated use of the VVTT seal verification process, management audit of seals
Procedural securityDocument processes relevant to transportation, handling and storage of cargo
Agricultural security (new)Requirements that protect the supply chain from contaminants and pests and the proper use of wood packaging materials
People and physical securityPhysical access controlsRequirements to prevent, detect or deter unauthorised personnel from gaining access to facilities; expands on the use of security technology
Physical securityPositive identification of all employees, visitors and vendors at all points of entry
Personnel securityComplete screening, pre-employment verification, background checks, and comply with U.S. immigration laws
Security training, threat and awarenessTraining on security for all employees, specialised training for employees in sensitive positions, determine if training was effective

CBP has begun informing affected entities of the proposed changes through webinars, weekly workshops at its field offices and workbooks that outline the updates each type of entity will need to implement. CBP will evaluate feedback received and make any necessary changes to the proposed MSC, which will then be finalised and implemented in the following four phases. In a document submitted to its Commercial Customs Operations Advisory Committee CBP indicated that CTPAT members will not be expected to adhere to the new standards until early 2020.

  • Phase 1: cybersecurity, conveyance and IIT security, seal security
  • Phase 2: security training, threat and awareness; business partner requirements; risk assessment
  • Phase 3: security vision and responsibility, physical security, physical access controls
  • Phase 4: agricultural security, personnel security, procedural security
Content provided by Picture: HKTDC Research
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