For joining us again. My name is Samantha Hurst, and I am here to support in the background of today's webinar focused on understanding and ranking down the U.S. Customs Enforcement executive order. Let's talk real briefly about some of our housekeeping items so we can get started. We do encourage you to join audio if you've not already, and if you happen to hear my voice twice, I am very sorry for the annoyance, but you might want to make sure that you are not joined in two different places. That could be the issue there. If you have questions throughout today's webinar, we do encourage you to put those into the Q&A box, not the chat box, but the Q&A box, and our team will work in the background. You've been on these webinars before. You know we seriously work through those and try to answer as many as possible before we wrap up. 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These are not new faces here, but unless you've joined us for the very first time, welcome. We have Madeleine Veigel. She's our Vice President of Customs for The Americas. Brenda Smith, whose lovely face just popped up on video. She's our Global Director of Government Outreach. Ted Henderson is our Senior Advisor for Customs, and Stephanie Holloway is our Director of Customs Operations. Now Brenda is going to get us kicked off. Thank you, Brenda. I am, and thank you, Samantha, and hello, everyone. Thanks so much for joining us today. It has been a busy August. We appreciate your taking time out to talk about this executive order that dropped in early summer. Before we get started, we wanted to issue our usual disclaimer, translated means we are not attorneys. We do the best we can to translate the policy and the legal documents that are issued by the U.S. government, and give you our best interpretation, but we are not attorneys, nor do we play them on television. With that, let's get started. As we dive into the environment that we are operating in from an enforcement perspective, there's a couple of key policy documents. The reason that we wanted to spend a little time on this is because what we have observed about the Trump administration is it is rare for them to take action without telegraphing it in advance. Sometimes the telegraphing comes very close to when an action actually happens. Ty pically, if you look at the documents, you look at the guidance, you will understand where the administration is going, at least in the general direction. O n Inauguration Day, one of the very first documents that President Trump issued was the America First Trade Policy. It was very broad, it was very sweeping, and had a lot of new ideas in it and new actions. That pretty much set us up for the 18 months since then. In early June, however, after a lot of the tariff activity and the agreements on reciprocal trade activity had kind of hit a consistent rhythm, we saw a new document, the Executive Order on Strengthening Customs Enforcement, which directs very specific action, most of which is to be taken by U.S. Customs and Border Protection. It essentially gives us a framework for how the government is thinking about enforcing current laws, making changes to either law or regulation, and doing an operational approach to enforcement. That was fairly quickly followed by the Department of Justice and the Department of Homeland Security issuing a pretty extensive guide, the Trade Fraud Resource Guide, which really outlined the enforcement priorities from both DOJ and DHS, and really sent up a red flag for those participating in U.S.-bound supply chains to really pay attention and make sure that all your I's are dotted and your T's are crossed because there is a renewed focus by the U.S. government to identify and address trade fraud. Then finally, and one might have thought that this would come out earlier, but it came out in August, just a week or two ago, something directly from the White House. Our assumption is that Peter Navarro, one of the president's key trade advisors, his team drafted a report called The Great Transshipment Scam. We are used to working with a very specific description of, or definition of transshipment. Mr. Navarro has actually kind of expanded the approach. He raises a number of points about goods moving between countries. How origin is not or could be verified, and the expectations around supply chain visibility. A lot of these ideas we have seen before, but this really puts the meat on the bones for the justification of why the Trump administration is taking the actions around enforcement that it is. T his is sort of the policy background for how CBP will be moving forward. With that, I'm going to turn it over to Stephanie, that will give us a little bit more insight into how that policy translates into the day-to-day. Thank you, Brenda. Okay, let's see here. My computer seems to have a mind of its own. As Brenda said, she just covered the high level policies. How are we actually seeing this play out day to day? This is where I love, not for enforcement purposes, but what I always like to look at, and what I like to bring to the table during these webinars, is the practical sense as a broker, how are we seeing this role? This slide shows, and we've talked about this before, on the left-hand side, this is activity or data that Expeditors has collected. As a broker, you often get copies of the CF-28s and CF-29s. That's a request for information, that's a CF-28, a very formal document that's sent. Or a CF-29, which is a notice of action or a notice of proposed action from customs, also a very formal letter. You can see here how it has jumped around and really made a significant jump in 2025. The other thing that you can see is that our general document request, these used to just kind of be emails informally sent from customs. That's almost completely disappeared. You can see the amount of CF-29s to CF-28s has significantly increased. Most of the time before the pattern was you would get a CF-28, you would respond, customs would come back or not with a CF-29. Now we're often just seeing a CF-29 issued and not a CF-28. On the right-hand side, there's some interesting data points. These are all published by customs. Customs actually has a number of dashboards. This particular data set is coming from a dashboard that's called CBP Trade Statistics. You can Google it or you can just use this link here. This is not secret information. You have access to it just like I do. But some of the signals per se that we're seeing on the ground is importer audits. Customs is actually doing less of them, but yielding much higher results per audit. Traditionally, you can see, I think their data goes to 2021. They used to yield about $200,000, $250,000 per audit. Last year, that took a jump to about half a million, $500,000, and they are trending almost $800,000 per audit now, doing less audits. You can really see when they go to do an audit, I think they already have the smoke, right? They know it. It's not a random thing. They really have intel. The other thing that we're seeing a lot more that their data is saying is liquidated damages. They're issuing much more of these. Liquidated damages are often issued if you have a late payment, not following a notice to redeliver, things like that. They are issuing many more of these, and then the way they group the amount they've collected is with penalties, so it's a little bit harder, but they have now exceeded, not by double, but close. Last year, they collected $46 million in penalties and liquidated damages, and this year, even though they're not through their whole fiscal year, they're already at $70 million. These are just some kind of random, not random, intentional stats that we pulled to help paint some of the picture of what's happening on the ground. The other thing, and we've mentioned this in passing before, is really understanding what is being issued. We know they're issuing more CF-28s and 29s, but what's in them and how are they asking for data? If you have not gotten a CF-28 or 29 from Customs in the past year, this is going to be very surprising to you. They are very different than what we used to see. These examples that I have here, I have anonymized, but these are ones that we got in the last couple of weeks. I didn't go dumpster diving for really hard, weird ones. This is just how they look now. If you get one, it's going to look like this. I used to see ones years ago that were like, "Send me your certificate of origin." That's it. Those days are gone. This CF-28, a request for information, they're already testing a specific claim. A lot of times we see like the one on the left is saying, "You claimed HTSUS heading 9802 U.S. goods, now prove it to me." "Show me all the activities and documents that support that claim." Same thing on the right, the United States-Mexico-Canada Agreement or any free trade agreement, it's really show me all the documentation and prove that to me. These are a little more robust than what we may have seen before. They just ask for a lot more things. It's important also to know that you have 30 days to respond to this. If you're looking at this, you should be thinking right now, how long would it take me to put this all together? This is a doozy of a CF-28. This one is really them asking for alignment between the product description and the value that was declared. They're saying, "I don't quite understand what this product is, and now please justify the value." I t's not just write me a little paragraph. It's give me, I need photographs, I need written descriptions. I need all of these things. T hen now go in depth on the value. Tell me exactly how you got there. Are there any additional charges that your company paid? Now who are all the people in the transaction? Once again, I have genericized this a bit, but I have tried to really keep the actual intent here so that you can see how they are coming. They are large and they are massive amounts. The other thing I'll touch on is this CF-29 sample. In this scenario, the importer had received a CF-28. They had responded. If you look in this first paragraph, it says, "You gave us a ton of documents." T hen Customs goes on, if you have time to read this, and I encourage you to, they're saying, "These documents you gave us aren't telling the full story. You can't justify the amount that you produced based on the documents that you are giving me. We don't actually believe that this could have been accomplished. Therefore, the country of origin that you're claiming is not correct, and we're going to change it, and you're going to pay a different duty amount." This should be very alarming and really make you understand or make you think about, it's not just accomplishing the task of getting the documents, it's making sure that they're telling the cohesive story. I think many of us, of course, have been using AI and things to look at documents and understand them. Of course, I think you should assume that Customs will be doing the same. If you get these requests, also trying to figure out how you actually make sure that they all come together and tell this story cohesively and back up what you've claimed on your entry. The last thing I'll point to as kind of an on-the-ground data point is the Department of Justice trade fraud cases. These are being highly public. They're putting the news alerts out on these. If you look here, look at the overall patterns. Don't get bogged down on each commodity. You're seeing them put them out on a very consistent basis. Of course, they're big numbers. Another theme that you're seeing is that they're using FCA, so that's the False Claims Act. I'll let you deep dive on that. That's not what this webinar is about. It's really looking at these common themes, and we're going to be talking about these, because they come up all over the place with enforcement right now. AD/CVD, country of origin, trans-shipment. These are the themes that are coming up, and we're seeing this. One other thing that I'll say is they have, of course, put together this fraud task force. As a broker, we are seeing some of that activity as well, also being asked in subpoenas and things like that for data and documents. Just to bring that home a little bit more, the Department of Justice is very active. They are asking for things, they are putting cases forward, so that the partnership between CBP and DOJ is stronger than we have ever seen it. I feel like that was really rough and a downer, but I'll hand it back to you, Brenda, to tie it a little bit more into the executive order and what we're seeing and thinking about that. Great. Thanks, Stephanie. We've given you the policy background, and we've given you the on-the-ground enforcement activity. What we want to do now is really do that deeper dive into the executive order that came out in early June. The executive order is only five pages long. Sounds like it's pretty dense, but you all read legal stuff all the time. We would strongly encourage you to read the executive order from start to finish. Here's the framework as you read it to be able to hang on different provisions. We believe that these are really the five big areas that are the takeaways from the executive order and capture what CBP and the administration is trying to accomplish with the actions taken as a result of that EO. The first one is the importer eligibility. When the EO first came out, there was a lot of discussion about importing shifting from a right to a privilege. There is a lot of language about importers in good standing and certification and vetting of importers. That is going to be a pretty critical change for those of us in the trade community, and we expect to see CBP issuing either policy guidance or, more probably, regulatory guidance. We also expect to see pretty significant advances in the requirements around supply chain information. Traceability has been a word that we have been hearing from CBP for the last 18 months, and as Stephanie pointed out in the CF-28 and 29 process, the supporting documentation requirements and the expectation of visibility is getting very strong. That continues to carry out as a theme. We are also seeing that if you do not get it right, that your ability to get a penalty mitigated down is going to be much more limited than it currently is, especially for repeat offenders. Going along with that supply chain visibility, we are seeing CBP really committed to earlier risk identification. They are expecting of both importers and brokers, earlier vetting of not only transactions but of business entities, and expect private sector players to be able to demonstrate that they have actually done this vetting. Then finally, we are seeing some interesting language around export records and the expectation that an importer will be able to provide any records associated with the export from the initial country of origin. Just keep in mind these five areas, and as you review the executive order, this is your framework. As we really think about who is going to be impacted, in our world, we often talk about importers and brokers. I n fact, if you parse the language of the executive order, you will see that there are many other parties to the supply chain that are likely to be impacted. Not just the importers of record, but those known as the beneficial owner. Stephanie, I have got that same speech issue. B eneficial owners and their affiliates, manufacturers and exporters, brokers, freight forwarders, custodians of bonded merchandise, and any other party involved in the transaction will be impacted by the executive order. It goes beyond customs declarations. It is about who is facilitating lawful or perhaps violative trade. There is a lot of things that we know and a lot of things we do not know as we look at the executive order. If we could go on to the next slide. We know the direction that CBP and the administration is going, and we have just kind of talked about that, and we have given you the flags for where you can find that information. We know what the priorities are, who the importer is, who owns the company, and whether traceability of entries can actually be demonstrated. We know the timelines, but just a small caveat to the 180-day calendar that is represented in the executive order. In our conversations with various government officials, they have pointed out to us that the executive order has language that is a little bit, I hate to call it fuzzy, but I will. It says things like, "CBP will start or will initiate." Which means that CBP has to get regulatory and legislative processes rolling, but they do not have to complete them within that 180-day timeframe. We are hearing much more likely to see this activity over the next 12- 18 months. We had also known the enforcement objectives, and we have kind of hit those pretty hard. We do not know, we do not have a lot of insight into the rulemaking processes. We do not know whether they will use interim final rules or notices of proposed rulemaking. We do not know what those regulatory packages will look like. We do not know what the implementing procedures will be, or the specifics around documentation and data. We do not know how CBP as a whole organization will be implementing those new requirements. There is a lot of things we do not know, but for now, we have a pretty good sense of where CBP is going. There is one more issue that we wanted to flag for you. In the past, we have often dealt with this idea of a foreign importer of record, and we know that CBP often sees a great deal of risk in companies that do not have a U.S. presence. In the executive order, that is certainly an area of focus. What we are seeing is a shift towards a definition of a foreign importer of record to someone or an entity that is financially responsible for the duties, for someone that does not have U.S. assets or bonding, someone who does not have beneficial ownership or business transparency, and whether at the end of the day, that importer can be held accountable for compliance. Whether they provide the data and the documents, whether they pay their duties, and whether a penalty can be issued and successfully collected. This is a new concept. Well, it is not a new concept. We believe the definition is likely to be new. A lot of change on the horizon, and Madeleine is going to walk us through what that means for importers. Gosh. Okay. Thank you, Brenda. All right, everybody. I just want to reiterate, actually the same point Brenda made earlier. I think I may have mentioned it on earlier webinars, but please, if you have not had a chance, please read that executive order. As Brenda said, it is only five pages, so it is not too long, but it is so important to review it and for you all to become familiar with what is in there currently. Again, I think this is, for me anyway, I think this is one of the biggest changes since 1993 and the Mod Act. This is a huge change. What we see with this executive order, and really some of the other things that Brenda talked about, some of the other policy directions that Brenda mentioned earlier, is that importing now really becomes more of a privilege versus a right. That is a huge shift that we all have to now understand and, anyway, trying to get our arms around. One of the things that this, and as you go through the executive order, one of the things you will see is that the administration wants to collect a lot more information about your company. There is information in that executive order about understanding and the administration wanting to collect information about your domestic assets, the year your company was organized, ownership of the company, disclosure or ownership disclosures, business affiliation disclosures, domestic asset disclosures. That is a lot more company specific information, and you may be asking, "Well, what does that really mean?" That is the question we are all asking. We do not know. The problem with this is that there is no official guidance yet from CBP or the administration in terms of what that really means. T hese are all kind of additional points that are stated in the executive order that the administration wants to collect. We are also reviewing internally as a broker what additional questions do we need to ask you as a new importer, for example, or even to our existing customers, do we need to collect this additional information? If we do, how do we even validate it, and what do we do with it? There are lots of questions. We do not have answers yet, but this is just to give you a flavor of some of the additional pieces of information that are mentioned in the executive order. In addition, they talk about the fact that in order to continue importing, you as an importer must be in good standing. Well, what does good standing mean? So far, the only thing we know for the executive order is that you have to be a compliant company and that you have paid all of your customs liabilities or any liabilities to the government. That is all we know so far. We are very much hoping that we are going to get more information here very soon on better definitions and guidance in both of those areas. C-TPAT, of course, is also mentioned, especially for foreign importers of record, that if they are not C-TPAT, they have to work with a broker who is C-TPAT. W hat does this mean for all of you? Since we are lacking a lot of detail and more official guidance, I think some of the things you can begin to look at are, do you have any outstanding compliance issues? I am thinking especially of companies who have maybe, if you have purchased a lot of companies over the past several years, and do any of those companies that you have purchased have any compliance issues that are outstanding or customs liabilities? These are things that you can begin to look at and review while we await for more guidance on what much of the rest of this still means. Anyway, these are some things, again, to begin looking at, compliance issues and outstanding compliance issues and customs liabilities. Okay. The other thing, and Brenda mentioned this too as we go to the next slide, is export documentation. This is really interesting, but the administration would like to collect the export declaration that was filed at the country of export. When you shipped your goods to the United States, the country of export, there was an export declaration filed. The U.S. administration is saying they would like a copy of that, and perhaps, and we don't know if that's the only thing they want to see, or if they want an entire document packet that includes maybe a packing list, a commercial invoice, maybe certificates that you had to file within the country of export. First of all, we don't know what all that comprises. Second of all, we don't know the timing. In other words, do you need to file that at the time the goods export the country of export, or do you need to file it at the time that we file the customs entry or sometime after the customs entry? Where in the heck do you file this information? Is this going to be filed via the document imaging system or DIS as we know it? Or will this be a whole separate application through which we file the export documentation? We don't know any of this. This is still very not clear, and this is one of the objectives in the executive order that CBP is supposed to start something on as of 1 September, which is next week. We don't have any further information. We'll see if any guidance or anything is issued next week. In the meantime, what would be good, one thing you can do is begin looking at, do you even have access to that export declaration? Do you know how you could even get access to it? That would be one thing to begin looking at, as an importer is, "Hey, can I even get my hands on that export declaration or any of the export documentation?" Again, a lot more information hopefully will be shared by CBP on how this requirement is going to be implemented. All right. The other area, and I should say that we've bucketed this into four areas, but the other one, and Brenda touched on this, is also the penalties. Actually, I think we have, maybe, Stephanie, I think we're maybe one slide ahead or before. I think there's one other just before penalties. Yes. Okay, perfect. All right. This was something Brenda touched on too earlier, and this is CBP looking at information further up in the supply chain. There's a couple things here that are in the works. First, there's of course, the additional information that CBP and the administration is seeking about the company or your company. Then there is also vetting that they're going to be doing, and they're going to be doing vetting of various parties. It's not just you as the importer, also the customs broker and several parties in the supply chain. In addition, what they highlight is prioritizing, specifically, you'll see that in the executive order, they're prioritizing forced labor, misclassification, undervaluation, and illegal transshipment. Aside from those four priorities, they also say that they would like to obtain detailed information about the imported goods supply chain and production methods. Examples of that are manufacturer's product identifier, model or style, key specifications. They're getting at some very intricate detail. We see, there's a couple things here. First, also what Stephanie Holloway noted earlier with the CF-29s, you saw how deep CBP is getting. We know that CBP is using AI. They've invested in AI, and they're using it a lot more. The expectation is that they are looking at more entities in terms of vetting, not just here, importers, brokers. They're looking at other entities upstream, and they're looking at more information and more detail upstream. We have talked about this before in other webinars, the importance of doing supply chain mapping. As you read through this executive order, you'll see this, and the importance of really looking at maybe your most critical, important products, and are you able to map them, map that supply chain all the way back to the origin. Again, as we have discussed before, do you know where the components of the actual manufacturing product or manufactured product come from? Where are they sourced from? Who is that entity? Where is that entity located? Really, beginning to look at supply chain mapping, I would say that would be one big takeaway or one thing you certainly want to look at. Then second, because they are prioritizing, again, forced labor misclassification, undervaluation, and illegal transshipment, the compliance of those core elements are going to be critical. We've talked about that also on previous webinars. The fact that, hey, can you provide the backup documentation in terms of how you arrived at the classification of your goods? How did you arrive at determining the country of origin? How did you arrive at the valuation or the valuation of your product? Having that backup documentation is so critical. That's another piece that you can really look at, especially maybe for some of your key or most critical products, because you can't boil the ocean all in one day. S tarting with the most critical products, really looking at, do you have that backup documentation? Do you know all the entities associated with the product that you're importing? Anyway, then kind of the fourth big area are penalties. This is something that we all have to look at very closely. This is worrisome, everybody, because first of all, the mitigation guidelines that exist today from CBP, those go back, I believe, to the early 2000s, some of the penalty mitigation guidelines. We have heard CBP is completely revamping those mitigation guidelines. Now they're looking at revised standards that establish a floor of at least 50% of the assessed penalty. That is a large amount, everybody, because we know that those penalty amounts can be quite large. If the minimum or the floor is 50% of that amount, that could still be a very large amount. Think about today, when we look at liquidated damages and penalties, especially like with the liquidated damage example of a late file penalty, where you ended up paying the duties too late to customs. You can mitigate those now down to $100, or if it's a periodic monthly statement, it could be $1,000. Anyway, those mitigation guidelines exist today. W ith this complete revamp, what is that going to look like? It's not just customs penalties, everybody. You have to think about, it's also ISF penalties, AMS, advanced manifest system penalties, in bond penalties. I t's across the board. As we all know, very highly compliant traders, highly compliant brokers, highly compliant importers, highly compliant transportation providers, we can all make mistakes and make simple mistakes, and that can result in a liquidated damage notice or maybe even a penalty. This is worrisome, and also the fact that the revised standards are going to eliminate mitigation for repeat offenders. This is also worrisome. The thing is, I think a few things to keep in mind. We cannot maybe just put this aside and say, "Well, I hope I'm not going to get a penalty." Because of course, hope is not a strategy. Or maybe saying, "Hey, I'll just put a bunch of money aside in case I do get a penalty." I think what you should do is look or begin to look for what kind of trends do you see right now in any, if you're getting any CF-28s or 29s, what are the trends that you're seeing? Is there a classification issue or claiming of a free trade agreement? Whatever it might be, look for trends. Look for trends in any penalties you may have seen, liquidated damages, audits, and then see what is the issue surrounding those trends, and then what can I do about it? What kind of control can I put in place? Is it a systematic control? Is it a process control? Is it a training control? I know this is a lot easier said than done, much easier said than done. T hese are things you can at least begin looking at while we await further guidance on all of this. I should also say that many of the associations, including ourselves, are providing CBP feedback. If you're part of an association, please make sure your voice is heard and you provide input on these areas, because we definitely need more guidance in order to figure out how this is all going to play out. I t is worrisome. Ted, I am going to. This is not very uplifting, any of this, but I'm going to pass it on to you. You can maybe help us with preparing for all of this scrutiny that's coming our way. Oh, yeah. I think it'll only get better during my section, so- I know. It's hard. If you can take an ice cream out and have a heck of a big party here. See if you can make ice cream out of this, Ted. Yeah. Thank you. As Madeleine said, I think I will lead off with kind of echoing one of our last thoughts. We get it. Sometimes we have no choice but to be reactive. Hopefully, after what you have heard from us so far, hopefully you agree that we should try to get ahead of what we anticipate will happen with the EO when it goes into full effect. Again, to echo Madeleine 's comments, for those of us who have been around for a while, this is the biggest darn deal since the North American Free Trade Agreement and the Customs Modernization Act went into effect a long time back in the 1990s. We first talked about the idea of a response model, really in the early days of the implementation of the UFLPA, the Uyghur Forced Labor Prevention Act. At that time, we said, "Look, if you wait until your container is detained, it will be too late to put together what you need to prove your goods are not connected to forced labor." The same logic applies here today. We have already given you examples of CF-28s and CF-29s. It really is time to be ready and make sure you have a protocol in place. Final note I will share is, I have talked about in the past that I started my journey in this industry at the old U.S. Customs Service. Even though I was second generation customs officer, I up and decided to join the dark side and became a customs compliance manager for a high-tech importer. I am going to say, I am sure my experience then is no different than what you live today. I did not have a team of 15 people, endless resources, nothing but free time. In our case, we had three different business units, a whole bunch of complicated stuff to import. We barely had enough people just to hang on. Frankly, we did not deal then with all the tariff actions that you are dealing with today. Again, I get it when we ask you to take some time to prepare, lay out a plan, do some preemptive testing of that plan. You, of course, will do it as soon as you put out your most current dumpster fire. Please bear with us. We are sharing this information. Hopefully, you will get a chance to build a plan, if you have not already, that you can execute against. Here are the five components of a response model that we put together for when CBP reaches out. Please understand, CBP reaches out to us just as they do to importers, so we do have some experience in this area. It is really very simple. First, number 1, there should be an owner. There should be an owner in any project, in any plan, whatever. Definitely in this model, make sure there is somebody who has the responsibility. Take the time to understand what CBP is asking you. What exactly is the claim that they are testing? What are they looking for? Then you assemble a packet. Hopefully, it is a pretty standard, consistent response packet that you have got together in your mind. We give you an example of that in the lower middle of the left side of this slide. Be ready to retrieve those supporting records. Then number 4, take the time to review and look not just at the individual declaration that customs is looking at, look at other like imports, related articles, things along that line. Then, once you put all this together, like anything, let's try to learn from what we did and look at the outcome. Could we do things better? Could we do things simpler? I will share this as a former customs officer. Carefully consider your response, that step four, that review page or spot. Don't be flippant. Don't just send a pile of documents to CBP with the attitude that they can figure it out. I will also tell you, most customs officer, and I certainly was an example of that, have zero experience in business. They didn't work for an importer or they don't, by and large, in my case, I got out of the Army, I went back to college, and I went to work for customs. I didn't know what a P&L was. I didn't understand any of that stuff. D on't just throw acronyms at them. Give them a roadmap, clear information, lay things out in a response packet. Measure your response. Don't give too much. Don't give too little. I know that's somewhat subjective, but think about what you're sending off to customs. Test this model, if you can, before you actually have to implement the model. Maybe you've gotten a CF- 28 or a 29 in the past that you had to respond to, or maybe there was an internal issue that somebody identified that was all hands on deck to try to sort out. Maybe you can use that as kind of a test and kind of run the plan as an after-action review and just say, "Okay, here's what we did on that scenario. Could we have done it better maybe using this model or something like that?" A gain, try to test the model and hopefully you're really prepared for when you do have to start responding to CBP in this new environment that we anticipate, or actually we're already in, but we expect it to get a little more severe as we move forward. All right. Let's really narrow it down to a single product and take this a step farther. In all of our recent customs market update webinars, if you've been part of them, we've talked about the importance of not just focusing on your overall supply chain, but the specific value chain of the individual articles you import. We've talked about that again today. J ust kind of continuing the theme of that previous slide, let's take this down a notch and how you would respond to an inquiry from CBP about a specific product. L et's take a look at the four points here on the left side of this slide. These are the things we've got to be able to prove to customs. Who made it? Not just who'd you buy it from, but go back farther in that value chain of the relevant suppliers of components and the manufacturers and things like that. What about country of origin? Not just the country of origin of the final article as it's coming to you, but how about the depth of the various articles that make up that product, and specifically manufacturing locations. We have seen examples already where CBP is taking a hard look at manufacturing locations, claimed manufacturing locations. Let's make sure that, you're saying a manufacturer is the Ted Henderson company in Penang. CBP will do some basic searches on the Ted Henderson manufacturing company in Penang and maybe come back to you with a shot from Google Maps that shows that actually the address you gave looks like a storefront for a convenience. They're looking, not only Madeleine's talked about, do they have AI tools? Yes. They're also working with third-party private sector companies who are providing a lot of interesting data elements to them that speak to international shipping patterns, and origin of products from around the globe, and can in many cases give a very good picture of what is a claimed manufacturing location and the fact that there have been zero inputs coming into that location, so how could it manufacture something? Look at the supporting evidence, that's bullet three there or item three. What supports all the things that you're trying to tell it? Then ultimately, how does it all connect? Again, the roadmap. Paint the picture for CBP. Explain how everything's connected so that it makes it easier for them to come to a conclusion, and you can guide the direction that they're going to go. Again, what should a test tell you? That whether you had a really nice, complete, connected story, whether you had records available but hard to paint the picture, or there are areas that are missing, and these are the areas that we need to dig into and make sure we can come up with something as things go forward. Document the gaps, assign that owner, repeat the test. Find something, once you do it with, say, an easy product, let's find something with a really complicated bill of material. Let's dig down three, four layers and make sure that we can actually do what customs expects us to do. All right. I mentioned UFLPA and forced labor and how the early implementation period of UFLPA, we worked through some basic concepts of preparing to validate your imports, then confirm that there's no forced labor connected to those imports. Maybe some of you joined those webinars several years ago, even though now it seems like a million years ago, we were talking about it. Yes, this webinar is focused on the recent executive order, but we do want to step back and revisit forced labor. We want to show you briefly how CBP's progressed in their actions, what they're expecting these days, and most importantly, we really want to take a look at a recent document that CBP released. My ask here is please, don't just ignore this section because you don't have goods that are even remotely connected to forced labor. I think that if nothing else, we can look at the most recent Section 301 forced labor actions, tariff actions that were put in place by the administration. I think we can understand that forced labor has relevance in a number of ways in the new world. About two months ago, CBP released a new document, the CBP Forced Labor Enforcement Operational Guidance for Importers. Comprehensive document, 79 pages, legal authorities, whole bunch of other interesting things. It really offers some really good transparency to CBP's enforcement protocols. Again, the learnings for all of us from this document should not just be focused around forced labor. CBP provides some really clear expectations about the things that they are applying in all sorts of inquiries, not just forced labor. Let's take a hard look at this document. We have a link to it here. The key thing in the really fine print on the two columns on the middle and right, these are the appendices in the document that really speak to very specific and very useful supply chain tracing information. There is also a whole bunch of other great information related to the UFLPA and legacy forced labor enforcement, WROs, whatever. This really gives you some excellent guidance by sector, by product, and some thought of how to engage in supply chain tracing and what CBP's looking at. Again, please, I know we've asked you to read the EO, I am going to ask you again, but also take a look at this CBP document and of course, the DOJ, DHS document as things are going. As we said at the outset, the administration is telling us something very important right now. We saw it in that EO, the DOJ, DHS trade fraud resource guide. Here CBP is laying out the operational environment that they are conducting enforcement operations in. Let's pay attention to what's being telegraphed as we look at it. All right. What do we hope you will take away from all of this last hour? First, we do not know everything yet. There is still much that has to be laid out, but we can definitely see the direction that the administration and enforcement agencies are going. For those of us who have been engaged in this U.S. import world for a few decades, the core concept that we've kind of just taken as a given, that importing is an unalienable right, that's no longer the reality. That first point, we really need to understand that CBP acting as the enforcement arm on behalf of the administration, is now much more concerned about making sure only the right people, the people in good standing, folks that are doing the right thing, are actually engaged in imports into the United States. Again, fundamental shift going on just in that concept. Second point, I've already said it once. We've said it across the thing, I am going to say it again. I beseech you, please read the documents we talked about today. Third, I know I am old school, but I want to remind you to focus on the fundamentals. When I was a young customs officer, it was all about classification, valuation, and admissibility. I took those same fundamentals with me when I ran off to be the head customs compliance nerd at that import. I want you to understand nothing's really changed in today's environment. The core statute that all of us operate under, as in U.S. imports, is the Tariff Act of 1930. For those of us who watched "Ferris Bueller's Day Off," remember the high school teacher, Ben Stein, talking about the Smoot-Hawley Tariff Act of 1930? Anyone? That's the same law that we operate under today. Those same core legal principles, that's what the current administration is using today with the EO and all of the other things we've talked about today. It's all built on that history. Focus on those historical fundamentals as we're moving through things. Finally, I've seen this so many times over the years as a customs officer and a customs broker. Folks only tend to look at an individual entry when CBP asks a question about that entry or that item on that entry. You have to think beyond the entry in question. Look at the whole value chain of an imported article. Look at the whole history of your imports of that article, because CBP definitely will. Make sure you're ready to support a larger discussion, not just about that one entry, but about everything that might be related to that. Bottom line, let's not wait until CBP starts issuing the implementing actions for the executive order, the Federal Register notices, new policy announcements, all of those things. As the prophet Bob Dylan said back in 1965, "You don't need a weatherman to know which way the wind blows." Let's get ready for where the wind's blowing right now. With that, we'll close this thing down. We'll look at the accreditation slide for those of us who are licensed U.S. customs brokers. We are getting close to the end of a triennial year. We hope that you've been taking advantage of all of our webinars and the opportunity to knock out some of your continuing education credits that you have to do as licensed brokers. We have more customs market updates planned for the remainder of the year, so more hours are on the way. P lease do take a look at your current credits and make sure you're set for that obligation when we renew in the new year. All right. With that, we do have five or six minutes. For my colleagues, any core things that we want to address as part of things you saw in the questions? Ted, I think I echo one of our commenters here. The fact that you quoted Bob Dylan, I mean, way to just bring this thing to a close. I have to quit webinars, everybody. Ted has surpassed. He is the master. Well done on that. A couple of things I do want to touch on that I saw questions about. One was about the, it's hard to remember time. There was a recent Federal Register notice about 5106s and making sure- Yeah. everything is updated. Once again, now that we have gone through the framework, we know what Customs is trying to do. One of the most basic things they need is to know how to contact you, right? That is why this Federal Register notice is published, because they need to make sure they have the right information on file. We are going to be looking at this. Samantha is going to be including a blog post that our colleagues over at Tradewin did on this topic, and we will be circulating that as well. Many of you will be completely fine. Your names and addresses and everything is fine. T his is once again a call because Customs, to implement any of this, they need to know who is out there and how to get hold of you. We will address that and send some extra materials on that. Oh, no, I was going to say something else super profound, but it fell out of my head. Oh, it came back. Other conversation in the chat about making sure that you have access to CF- 28 and 29, and not wasting any minutes on that. I do not know if I said this clearly during my section, but a line that is now being, it almost feels like pre-printed on CF- 28, is, "We will not issue any extensions." That used to be really common practice, was that you could go to customs and ask for an extension. We are not seeing that now. Y ou cannot waste any of your 30 days, going to mail stops, you are working from home, whatever it might be. M ake sure that you have a process in place, ideally in your ACE portal. There is a report, somebody said it is the ES13, do not quote me on that, where you can get a notice. There is also a form section, and I think importers have said you need to watch both because they are not always in sync. J ust please look at that. That is an area as a broker where our system does not quite align perfectly, so it is hard for me to answer that completely. T hank you. Thank you so much for attending. Anybody else on my colleague's side want to chime in? I think you have got it all, Stephanie. Please read- No. Actually, the only other thing that I would add, Stephanie encouraged, or Madeleine encouraged you all to work with your trade associations. Oh, yeah. Take the opportunity to submit comments. I think there's a groundswell of interest. CBP is listening, and we just want to try to get ahead of the open questions. Be sure you're participating. Your trade association's a good place to start. Yeah. Absolutely. Very good, everyone. Well, thank you so much for joining. I am also very happy that others picked up on the Ferris Bueller comments as well. That was fantastic. Appreciate that. I think everybody's having fun with that levity. Just a reminder, if you are looking for the materials or maybe your sound wasn't working and you want to hear part of the recording, I know we've had a couple people that had those issues, we're going to get the materials to you. Keep your eye out for the survey that will be emailed to you here in about an hour, and that's the easiest way. As soon as you finish the survey, a link pops up. It will say, "Thank you for participating," and you'll get your link to materials. T hat's the easiest way to get access to that. A gain, we just appreciate you all participating. If you have any questions or need a follow-up meeting, that survey will also give you an opportunity to request that meeting. Thank you all for joining. Team, great job as always. Thanks, everybody. Thank you all. Take care. Thank you, everybody. Bye. Bye-bye