CBP Updates Insufficient Bond Information

On March 2, 2011, CBP posted an update on insufficient bonds.

The document provided a list of reasons a continuous bond may be deemed insufficient, which include

• Outstanding debt issues related to any of the entities on the bond (including unpaid bills and debit vouchers)
• Failure to comply in a timely fashion with a formal demand letter from CBP to increase the bond
• Use of an invalid or ‘non-deliverable’ address for any entity using the bond
• Failure to comply with the rejection of a termination request
• Missing or misplaced bond paperwork
• Use of an invalid importer of record number on the bond (ex. an entity using an EIN that is not assigned to that party by the IRS)
• Failure to provide any required bond paperwork (ex. Reconciliation rider, bond rider for importation into the U.S. Virgin Islands, surety approval for participation in deferred tax payment, etc.)
• Failure to annually deposit the required cash-in-lieu of surety for a continuous bond obtained under 19 CFR 113.40 
• Failure to comply with specific mandates/requests from the Office of Administration

CBP found that some parties continued to use bonds that were deemed insufficient.  Effective immediately, the Bond Team may take one or more of the actions that follow when they identify a principal has been made aware of an insufficiency and continues to use the bond.

• The Bond Team will review other continuous bonds used by the principal and may be deemed insufficient as well.
• The Revenue Division, in conjunction with the Ports of Entry, may input cargo criteria to preclude immediate release of the principal’s goods.
• As a last resort, the importer record may be voided.

Click HERE to view the updated Insufficient Bond notice.