Meeting the Minimum Security Criteria (MSC) for the CTPAT Risk Assessment
Whether you’re new to CTPAT certification or are preparing for validation or recertification, the U.S. Customs and Border Protection’s (CBP)...
5 min read
Admin : Dec 7, 2023 12:50:49 PM
In 2019, U.S. Customs and Border Protection (CBP) updated its minimum security criteria (MSC) to address changes to the global supply chain and the threats it currently faces. The updated CTPAT minimum security requirements include three focus areas:
Corporate Security
People and Physical Security
Transportation Security
The CTPAT program came about after the 9/11 terrorist attacks and is an effort to strengthen border security and facilitate global trade. Importers that receive CTPAT certification can receive various benefits.
To become certified, organizations have to meet CTPAT minimum security criteria (MSC) requirements. Each type of business entity has specific minimum security requirements that they need to meet. The CTPAT MSC establishes the security standards a company must implement and keep up-to-date to participate in the program.
Given that the CTPAT program was founded based on border security, it only makes sense that corporate security is the first focus area in the CTPAT MSC for importers. Of equal importance to corporate security are the second and third focus areas of the MSC for foreign manufacturers: people and physical security and transportation security. Read on to learn about each of these.
For each focus area in the CTPAT MSC, CBP provides criteria, implementation guidance, and whether it is a “should” or “must” be completed. You can read more about the most recent detailed minimum security criteria from CBP.
Senior leaders at a given foreign manufacturing company must be fully committed to their supply chain security and the minimum security criteria. CTPAT MSC should be prioritized by leadership and be part of the company culture, with an emphasis that it is everyone’s responsibility.
In addition, a written review component is required to ensure that employees are indeed following the company’s security policies. A rock-solid security vision as a minimum security requirement permeates everything the company does and is easily identified and followed by each employee.
To confirm this engagement, the CBP wants to see a “Statement of Support” that is submitted with the MSC Security Profile (or Annual Review) and is signed by the executive staff pledging to maintain the CTPAT MSC.
With the threat of terrorist groups and criminal organizations targeting supply chains around the world, it’s no wonder that one of the annual CTPAT minimum security requirements for importers is a risk assessment, used to assess existing and potential exposure to these evolving threats. There are many factors that CTPAT importers need to consider when determining risk within their supply chains, including its business model, geographic location of suppliers, and other aspects that may be unique to their specific supply chain. Importers need to identify threats, assess risks, and incorporate sustainable measures to mitigate these vulnerabilities and meet MSC requirements.
The external risk assessment for MSC typically takes the form of a “Risk Map," which can be a visual map, diagram, or spreadsheet that plots the risk across the various regions served by the manufacturer. Having accurate information on each region is part of the challenge of this effort that leads towards meeting MSC requirements and is why many manufacturers leverage outside help in this area. The exercise helps the company identify “hotspots” and, more importantly, aligns all stakeholders with potential risks incurred by operating certain locations.
The internal risk assessment for MSC is also a requirement. This is usually a document that outlines all the measures a company puts in place to maintain security at the office and warehouse level and identifies gaps that exist.
As is the case with most companies, importers likely have business partners, both domestic and international. Not only does the potential CTPAT member need to ensure they are following secure supply chain practices and minimum security requirements, but its partners need to as well.
Business partners include those involved in the document preparation, facilitation, handling, storage, and/or movement of cargo of a CTPAT importer or exporter member. If a member happens to outsource any part of its supply chain, it must ensure that these partners have stringent security measures in place and that they also follow the CTPAT minimum security criteria. Some ways to do this include conducting an onsite audit or security questionnaire.
The most common device used to judge a partner’s adherence is an MSC security questionnaire. Although the format of a minimum security criteria security questionnaire varies greatly, it usually contains anywhere from 50 to 100 questions related to overall security encompassing the 12 sections of the CTPAT MSC requirements. After receiving a completed MSC questionnaire, the goal is to be able to assess a partner’s fitness to perform security functions related to documenting or handling cargo.
Business partners add an extra layer of complexity to the risk analysis equation and being able to meet MSC requirements. As long as they meet or exceed the minimum security CBP requirements, there will likely be no issues for the potential CTPAT member. If red flags are raised, some steps can be taken to rectify them.
You’re likely no stranger to cybersecurity. It has and can affect businesses of any type and size. Today’s definition of terrorism now includes various types of cybercrime, making cybersecurity requirements no surprise for adhering to minimum security criteria and becoming a CTPAT member.
The first step is getting comprehensive cybersecurity policies and procedures in place to meet MSC and committing to reviewing and updating them regularly if necessary. This focus area also addresses the proper securing of IT systems: working remotely, cyber policies, cyber inventory, and backing up data. CTPAT requires organizations to take several measures through CTPAT minimum security criteria to mitigate the risk of a cybersecurity breach.
The need for physical security varies by organization, but when you’re a manufacturer that handles cargo, sensitive equipment, and/or information daily, some basic security measures need to be in place to satisfy MSC requirements. The “people” portion of this CTPAT minimum security criteria refers to the human resource force at a given organization.
Physical barriers and deterrents are needed to ensure unauthorized individuals do not gain access to confidential information and equipment.
People who are involved in shipping, receiving, driving, and security must be reliable and trustworthy, making thorough pre-employment verification and employee screenings crucial.
Other practical applications of physical security for minimum security criteria requirements include:
Making sure people cannot access offices or cargo storage without an access key or first checking in with a supervisor.
Checking visitor IDs and keeping a log of all visitors.
Verifying that all alarms, cameras, and other security equipment are working properly.
Training all employees on what to do if an unfamiliar person enters the building and tries to gain access.
Criminal background checks on all associates.
Other ways to prohibit access to cargo and shipment information without proper vetting.
Another minimum security requirement for CTPAT membership is transportation security. Breaches in supply chains occur most often during the transportation process, which is why these key cargo criteria must be upheld as minimum security requirements and by CTPAT members.
Instruments of International Traffic (typically containers or trailers)
Seal Security
Procedural Security
Agricultural Security
Making sure your company has policies in place for each one of these areas is critical as a minimum security criteria requirement since employees and business partners must be able to fully understand your Standard Operating Procedures (SOPs).
If you’re a bit overwhelmed after reading through the CTPAT minimum security criteria requirements for importers, you’re not alone. Even if you’re already doing most of the MSC requirements, documenting them can be complex and time-intensive.
The good news is that Veroot is here to help! Our team of CTPAT MSC consultants and CTPAT management software could be the resources you need to earn that coveted certification. With our CTPAT MSC software, you can automate the entire compliance process and ensure you meet CTPAT MSC requirements, saving your team precious time and effort.
After you’ve become CTPAT certified, the Veroot software doesn’t stop working for you. Each year, you are required to maintain your certification and will likely be audited by CBP, which includes CBP ensuring MSC is maintained. Easily show your proof of compliance anytime, anywhere, with our software. In addition, Veroot customers save an average of 85%-90% of the time they used to spend managing their CTPAT membership the old-fashioned way.
As a foreign manufacturer, being able to show your current and prospective customers that you’re committed to becoming CTPAT certified through meeting MSC requirements builds trust, improves your brand, and strengthens the global supply chain. Don’t let the minimum security requirements overwhelm you. Veroot is here to make CTPAT compliance less complicated, and we’d love to help. Schedule a demo today!
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