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From CBP: CTPAT Criteria Modifications: Regarding the new minimum security criteria, after further consulting with the trade community, and following their recommendations, CTPAT recently updated Criterion 7.37 to read as follows: 

Criteria: Following a significant security incident, Members must initiate a post-incident analysis immediately after becoming aware of the incident and in order to determine where the supply chain may have been compromised. This analysis must not impede/interfere with any known investigations conducted by a government law enforcement agency. The company’s post-incident analysis findings must be documented, completed as soon as feasibly possible, and, if allowed by law enforcement authorities, made available to the SCSS upon request. Implementation Guidance: A security incident is a breach in which security measures have been circumvented, eluded, or violated, and have resulted or will result in a criminal act. Security incidents include acts of terrorism, smuggling (narcotics, human, etc.), and the presence of stowaways. Should companies have questions on CTPAT Trade Compliance issues, they may send them to this email box:

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