On May 14, 2015 U.S. Customs and Border Protection (CBP) began the final enforcement of the Importer Security Filing (ISF).
The new guidelines which were announced in a webinar on May 5, 2015 authorize local ports to issue liquidated damages without obtaining headquarters’ approval. The local ports will no longer be required to submit three warnings prior to issuing penalties. The strategy provides for local discretion at the port, and does allow officers to continue to submit three warning letters to noncompliant importers.
The changes noted in the webinar apply to the ISF-10 only.
CBP is currently working on an updated FAQ document and you can find a copy of the webinar here: http://www.cbp.gov/trade/stakeholder-engagement/webinars