Members operating ships which trade to the United States will shortly be required to comply with new Automated Manifest System (AMS) regulations. In order to do so, those concerned will also need to obtain a Standard Carrier Alpha Code (SCAC) and an International Carrier Bond (ICB). The requirements enter into force on 4 March 2004. In view of the very short lead time, it is important that Members take action without delay. Background The US Maritime Transportation Security Act was introduced to improve the security of cargo shipments entering or leaving the United States by sea, air, rail or truck. The Act passed into law in 2002 and requires the mandatory submission of cargo manifest information by electronic means. The US Bureau of Customs and Border Protection (CBP) was charged with implementing the new law and a Final Rule was published a short time ago setting out the details. Application The AMS regulations will affect all ships bringing cargo into US ports including all US non-contiguous and island territories, even if the cargo is not to be discharged in the US and is to be consigned to foreign ports. It is possible that the regulations may not apply in situations where a customs entry is not currently required (e.g. Louisiana Offshore Oil Port (LOOP), ship to ship transfer operations offshore), but this issue remains in need of clarification. An AMS declaration is also required for cargo loaded in US ports. Carrier The SCAC, ICB and AMS reporting requirements apply to ocean Carriers and to Non-Vessel Operating Common Carriers (see below). CBP has defined the Carrier as "the entity that controls the conveyance" such as the head owner or the bareboat charterer. It is thought that a manager may be construed as being the Carrier if it is clear that the manager has assumed responsibility for the operation of the ship, but this should be verified with CBP in the first instance. It is less clear whether a time charterer may be deemed to be the Carrier, and CBP ma