Yes, there can be a penalty if there is no AMS match prior to the cargo’s arrival in the U.S. You should continue to query the bill of lading in AMS to get a match so the ISF will be considered complete and accurate prior to arrival of the cargo in the U.S. to avoid any potential claims. Per CBP, if the no-match is caused by the carrier, CBP will not consider the ISF Importer of Record to have been in violation and subject to a claim.