CTPAT MSC for Brokers in 2020


CTPAT Executive Director Manny Garza and Branch Chief Carlos Ochoa participated in a tele-conference with a few members of the NCBFAA Customs committee last month for a discussion on expectations for broker CTPAT participants for the Minimum-Security Requirements. Points of interest from the call:


Compliance with the new Minimum Security Criteria (MSC) is effective January 1, 2020.

CBP is expecting members to be ready, but validation visits may be delayed until late February or March.  The government budget is affecting scheduling.

25% of all the CTPAT members will be scheduled for Validation in calendar year 2020.

CTPAT Portal – look for many updates in the Documents section under Public Library. Most are specific to industry membership, i.e. Customs Brokers, Importers, Sea Carriers, etc.

CBP expects members to go into Portal for updates. CBP doesn’t always send out electronic messages.

All CTPAT members, including brokers, are expected to have a Team for internal oversight and compliance.

CBP is looking for internal leadership involvement.

CTPAT members can start to draft their profiles and responses for their MSC.  The participant’s profile can be shared with their SCSS before loading into the portal

Adding company Code of Conduct for expectations for acceptable behaviors.

There is  a 4-year validation cycle, but CTPAT participants are still required to update their risk assessment every year.

The new minimum security criteria are more performance based instead of prescriptive.

Future CBPO CTPAT Point of Contact (POC) at the Ports of Entry


Sub-Committee Chairman Rene Romero adds, “the conversation brings several recommendations to our members.  If you haven’t peeked at your Portal, you’ll find plenty of reading to catch up for preparation under the changes in the MSC.  Go to the Trade Account Information box and link to Documents, then click Public Library.  Publications are listed by industry type member.  You’ll be surprised to find 34 publications since September 2019 with some posting as recently as November 27th.  CBP doesn’t always send out a message and the messaging system within the portal doesn’t always work. Brokers should review and update their designated Points of Contact  We should be expecting more messages through the Portal so check regularly.  The NCBFAA will have a follow up meeting with Executive Director Garza in early January.  In the meantime, we ask our members to send us comments and questions.  This can be through your Area Customs Committee representative who can forward to the whole Customs Committee and the CTPAT Subcommittee.”

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