CTPAT Withdrawal, Suspension, and Removal: What You Need to Know

The Customs Trade Partnership Against Terrorism (CTPAT) program is a vital component of U.S. Customs and Border Protection’s efforts to secure the global supply chain. While participation in the program offers significant benefits including reduced inspections, expedited processing, and access to trusted trader programs - it is also a privilege that must be actively maintained.

Let's explore the key distinctions between Withdrawal, Suspension, and Removal from the CTPAT program, helping members understand the implications and how to avoid losing their membership.

Voluntary Withdrawal from CTPAT: 

A withdrawal occurs when a partner chooses to leave the program on their own accord. This is a formal process initiated by the partner, not CBP.

Common Reasons for Withdrawal:

• Company restructuring or acquisition
• Lack of resources to maintain program requirements
• No longer engaging in international trade
• Shifting compliance priorities

How to Withdraw:

• The partner submits a written request through the CTPAT Portal. (Email is acceptable)
• The request must include the reason for the withdrawal and be requested by the designated CTPAT Security Point of Contact (POC).
• CBP will update the partner’s status to close the account
  • Connected CTPAT certified business partners will be notified of a change in the status with the withdrawing company
  • The Trade Account will be removed from the CTPAT Portal.

Implications:

• Loss of CTPAT benefits (e.g., FAST lanes, reduced inspections).
• Re-application is possible but requires a full re-evaluation as a new applicant

Suspension from CTPAT: 

A suspension is a temporary action taken by CBP when a partner fails to meet the program’s minimum security criteria or becomes non-responsive.

Common Triggers:

• Failure to submit annual security profile reviews by the due date
• Failure to up date polices and lack of evidence of implementation
• Major security breaches (e.g., tampering, smuggling, criminal activity)
• Unresolved vulnerabilities identified during validations
• Inadequate corrective actions following a violation
• Not monitoring Business Partners or doing business with non-compliant partners

Consequences of Suspension:

• Temporary loss of all CTPAT benefits
• More inspections and longer delays at ports 
• Company is placed in a probationary status
• Connected CTPAT certified business partners will be notified of a change in the CTPAT status
• Must submit a corrective action plan within a specified timeframe

Reinstatement Process:

• CBP reviews the submitted plan and conducts follow-up evaluations
• If corrective actions are verified, CBP may lift the suspension and restore benefits
  

Removal from CTPAT: 

Removal is the most serious action and signifies the termination of a partner’s membership. This may follow unresolved suspension issues or egregious violations of program requirements.

Grounds for Removal:

• Failure to respond to suspension or submit adequate corrective actions
• Repeated violations of security criteria
• Involvement in illegal activities (e.g., narcotics trafficking, fraud)
• Providing false or misleading information to CBP

Effects of Removal:

• Immediate and permanent loss of all benefits
• Notification sent to all relevant CBP offices and partner agencies
• Connected CTPAT certified business partners will be notified of a change in the status with the withdrawing company
• Public image and business reputation may suffer

Reapplying After Removal:

• Reinstatement is not automatic and typically involves a multi-year wait
• Requires substantial evidence of improved compliance and security posture

In Summary

Participation in CTPAT is a sign of a company’s commitment to secure trade and customs compliance. Withdrawal, suspension, and removal from the program not only eliminate access to key benefits but may also impact business credibility and customer trust.

To remain in good standing:

• Stay current with annual reviews and portal updates
• Address vulnerabilities promptly
• Foster a culture of continuous improvement in supply chain security

At Veroot, we help companies maintain compliance and avoid these pitfalls through expert consulting and comprehensive security planning. If you’re unsure about your CTPAT status or need support during a suspension or reapplication, we’re here to help.

For more information or to request a demo, visit Veroot's website at www.veroot.com/ctpat