U.S. Customs and Border Protection officials recently announced that beginning January 26, 2010, they will take a "graduated escalated enforcement" approach to the full enforcement of the 10+2 interim final rule that amended 19 CFR to require Security Filing information from importers and additional information from carriers for vessel (maritime) cargo before it is brought into the U.S.
Officials stated that CBP will not be issuing any liquidated damages during the first quarter (until April or May 2010), and will instead be issuing warning letters. During the second quarter, officials state that CBP will put shipments on hold and issue liquidated damages in certain circumstances. CBP is expected to take an even more enforcement-minded approach in the third and fourth quarters.