Is CBP 'Management By Account' Becoming A Reality?

The concept of Management by Account (MBA) is not new. Sometimes referred to as Account Based Processing or Account Management, the concept of viewing an importer's business from a more holistic approach has been under discussion between the trade and U.S. Customs and Border Protection (CBP) for years. For numerous reasons, however, the idea has languished and never truly moved forward. Now, with efforts by the Commercial Operations Advisory Committee (COAC) and support from CBP Commissioner Bersin, the initiative appears to be taking off.

Background

The concept of Account Management (AM) was developed by CBP in 1994 as a key driver to achieve commercial compliance with large importers representing roughly 70 percent of commercial imports into the United States. The idea was that by CBP focusing on the internal compliance controls of these large importers, the importers would achieve a higher degree of trade compliance, leveraging an enterprise account model rather than a "transactional approach," which means assessing or inspecting each shipment or reviewing each entry declaration by these companies.

The stated purpose of AM was to establish "government-business relationships that are critical in building a solid foundation of open communication and trade facilitation" and to become "a cornerstone of the U.S. Customs Service risk management approach".

In 1997, CBP created the position of the National Account Manager (NAM) for a number of large importers. The stated benefits provided to importers assigned a NAM "include but are not limited to: access to company data relative to CBP examinations, advance notice on CBP program and policy changes, facilitation with discerning importers (or broker's) problems and trends, assistance with determining bond sufficiency, among others. Account Managers focus on improving a company's compliance and internal controls in order to help reduce CBP examinations. The Account Manager acts as the primary point of contact for all CBP issues and provides the best customer service possible." In addition to certain large importers, those importers participating in the Importer Self Assessment (ISA) program were also provided a NAM as a benefit of participation.

Despite the efforts made, the concept of AM has yet to achieve its goals. Currently CBP has 33 full- time NAMs in 19 locations. Additionally, there are a few hundred Port Account Managers (PAM) who are only nominally engaged in the program. With the top...