U.S. Customs and Border Protection (CBP) developed the Customs Trade Partnership Against Terrorism (CTPAT) due to the terrorist attacks of September 11, 2001. This voluntary program called on members of the trade community to help Customs develop guidelines to strengthen supply chain security worldwide. While there have been minor updates and changes in the program, the first significant revision was the Minimum Security Criteria (MSC), published in May 2019. The revision resulted from a two-year collaboration between the CCOAC (Commercial Customs Operations Advisory Committee), CBP and the trade community. The new Minimum Security Criteria was designed to address the current challenges faced on a global level.

Minimum Security Criteria Updates

The Minimum Security Criteria updates contain five new areas of focus, outlined below:

1. Cybersecurity
   Working in a digital world requires an enhanced system to protect a company’s most precious assets, including but not limited to customer data, intellectual property, financial records and employee records.
   
   Example: CTPAT members must have comprehensive written cybersecurity policies and procedures to protect IT systems.
   
   
2. Protections Against Agricultural Threats
   From loading the container at the foreign warehouse to loading the container on the vessel, there is an ever-increasing need to protect the supply chain against pests that could undermine the ecology of the United States. 
   
   Example: CTPAT members must, per their business model, have written procedures designed to prevent visible pest contamination, which includes compliance with Wood Packaging Materials (WPM) regulations. Visible pest prevention measures must be adhered to throughout the supply chain. Measures regarding WPM must meet the International Plant Protection Convention’s (IPPC) International Standards for Phytosanitary Measures No. 15 (ISPM 15).
   
   
3. Anti-Money Laundering and Counter-Terrorism
   With the use of the web and other sophisticated electronic means, money laundering schemes are even more challenging to detect. Money laundering often funds terrorist groups; thus, there is a new focus on awareness.
   
   Example: CTPAT members should provide annual specialized training to personnel who may be able to identify the CTPAT Warning Indicators of Trade-Based Money Laundering and Terrorism Financing.
   
   
4. Improved Physical Security Requirements to Protect Cargo and People
   An increased focus on steps that CTPAT members can take to limit or prevent unauthorized access to data storage and cargo storage, including perimeter measures, cameras, improved IT systems and access control.
   
   Example: Companies must physically secure all security technology infrastructure from unauthorized access.
   
   
5. Enhanced Focus on Vision and Responsibility From the Top Down
   For a CTPAT members’ supply chain security program to become and remain effective, the company’s upper management must instill security as an integral part of the culture. 
   
   Example: A company should incorporate representatives from all relevant departments into a cross-functional team focused on building a robust Supply Chain Security program.
   

The Minimum Security Criteria also includes a new “risk-based approach” to the categories in the program. Some categories are classified as a “must” and some as a ”should;” however, CTPAT participants must address all criteria.  

When Do the Changes Take Effect?

Validations under the new criteria are being phased in for 2020/2021 validations. Each CTPAT participant will be affected differently by these updated MSC’s but will be responsible for communicating the changes to their foreign partners, local warehouse facilities and every party in between. 

If you are looking for more information about the CTPAT program, you can find updated information that corresponds with your role in the supply chain by visiting their website.

Ascent Global Logistics is a proud member of the CTPAT Broker and Consolidator sectors and has participated in the program since 2003. This month, we celebrate our involvement in CTPAT, and we encourage others to participate.

Who said logistics has to be complicated? We certainly didn’t. Contact our experts to learn more about Trade Compliance.