The Advisory, Conciliation and Arbitration Service – ACAS update

ACAS moved into the penalty phase June 11th
CBP does not have good stats yet on how much filing is being done
A rough guess is 85% covered by ACAS filings, although the market suspects it is less as many parties are far from being ready
CBP is not trying to hammer parties who are not filing; there is a lot of good faith to get filings made for those who are not filing
ACAS penalty period will begin with warning letters as first steps
If there is a pattern, fines will be issued
ACAS enforcement is being centralized at the National Targeting Center
For the interim period it is advised that filing should go through the air carrier