supply chain security, internationa trade law, page fura

Supply Chain Security

Supply Chain Security and acronyms such as ISF, C-TPAT, PIP and AEO have suddenly become an integral part of any company involved in global trade. These exact terms have led the world to reevaluate world commerce by focusing on a principal means – the product supply chain – for the protection and safeguarding of international borders. That, in turn, has led to the creation of a meld of trade facilitation, trade enforcement and supply chain security found in the concept of "Trusted Trader."

At Page·Fura, P.C., we recognize the challenges and opportunities such programs as the United States's Customs-Trade Partnership Against Terrorism (C-TPAT), Canada's Partners In Protection (PIP), the World Customs Organization's SAFE Framework/Authorized Economic Operator (AEO) and the impact of Mutual Recognition Agreements (MRAs) present to global trade, and the vigilance required to comply with their ever-changing standards as well as .

Our representation in Supply Chain Security includes:


Representation and Support in CBP Security Validations/Revalidations
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Both initial and on-going program eligibility is verified through the conduct of domestic and foreign security validations and revalidations by U.S. Customs & Border Protection ("CBP") Supply Chain Security Specialists ("SCSS"). While CBP focuses on C-TPAT's minimum security criteria and the 5 Step Risk Assessment approach, there is room for subjectivity and reasonable minds will differ. We help companies prepare for such validations/revalidations by performing mock reviews, while also participating in those validations/revalidations to ensure that a fair evaluation reflective of our clients' security practices is conducted.
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Self-Assessments
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Using CBP's 5 Step Risk Assessment Model as a base, we develop tailored questionnaires, interviews and on-site reviews of container, physical, personnel, procedural and information system security, we provide companies with an assessment of their current ability to meet border/supply chain security requirements. Our report – which is provided under the attorney-client privilege – provides companies with the feedback needed to support current initiatives, while also noting best practice opportunities for improvement to ensure acceptance and on-going compliance with CBP's border/supply chain security expectations.
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Internal/External Business Partner Coordination
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From a company's external sourcing, consolidation, warehousing/distribution and transportation business partners to its internal product design and engineering, sourcing/purchasing, manufacturing, transportation/logistics, audit, finance/accounting, security and trade compliance functions, perhaps no area of a company's business touches as many functional areas as product supply chain. At the same time, however, while these areas work successfully at getting product to market, they are not always as successful at achieving the same goals from a security supply chain perspective. We work with both internal and external resources to increase their awareness of the critical role everyone plays in supply chain security.
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Manuals, Policies & Procedures
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As with other aspects of cross-border trade, written manuals, policies and procedures are essential tools for certifying a company's supply chain security program. We work collaboratively with our clients' security, internal audit and compliance personnel to develop targeted, dynamic documentation designed to meet the evolving protocols of border security.
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Security Training & Threat Awareness
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A key element of any supply chain security program concerns the training provided to company personnel and external business partners. Of all of the areas reviewed by both governmental and private sector security specialists, this has repeatedly been identified as an area for process improvement. Our training helps company personnel/business partners become better "eyes and ears" by sensitizing them to potential avenues for gaps in supply chain security, while also ensuring that they do not themselves inadvertently permit such breaches to occur.
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Vendor/Supply Chain Business Partner Surveys/Evaluations
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Since a supply chain is only as secure as its weakest link, we work with companies to develop questionnaires and other surveying materials for dissemination to all supply chain business partners from the point of manufacture through the point of receipt. We then review the information received and work with our clients to determine what – if any – further interaction/evaluation is required with business partners to ensure supply chain security.
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