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RENZA, INC. Anatomy of a Drug Seizure July 15, 2009 WMTA. Anatomy of a Drug Seizure . CBP has to distinguish the good guys from the bad guys Inadvertent acts can make you a bad guy Seizure Involves: Shipper Carrier Broker Importer. Anatomy of a Drug Seizure . Possible CBP Actions
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RENZA, INC. Anatomy of a Drug Seizure July 15, 2009 WMTA
Anatomy of a Drug Seizure • CBP has to distinguish the good guys from the bad guys • Inadvertent acts can make you a bad guy • Seizure Involves: • Shipper • Carrier • Broker • Importer
Anatomy of a Drug Seizure • Possible CBP Actions • Conveyance Seizure • C-TPAT Suspension • Penalty Notice & Demand for Payment • Post Incident Analysis • These will occur simultaneously
Anatomy of a Drug Seizure • Purpose Post Incident Analysis (PIA) • Who?, What?, How? • Used to prove good security procedures (or the lack thereof) • Used to reinstate C-TPAT status • Can be used as basis for penalty mitigation
Anatomy of a Drug Seizure • Post Incident Analysis (PIA) • Each party may conduct own PIA (Carrier, importer, shipper, broker) • CBP will conduct its PIA(s) • C-TPAT SCSS • Local Port Officers • ICE
Anatomy of a Drug Seizure • FAST is not the biggest C-TPAT benefit • Seizures are expensive & time consuming • Always position your company in a defensible posture • Make your company a “hard” target • Make use of outside resources
Anatomy of a Drug Seizure Questions? RENZA, INC. 619 661 6388 rlreneau@cox.net