STRATEGIC PLANNING FOR Post-Clearance Audit (PCA)

Transcript:STRATEGIC PLANNING FOR Post-Clearance Audit (PCA):
STRATEGIC PLANNING FOR Post-Clearance Audit (PCA) (based on WCO PCA Guidelines, Vol.1) “A structured examination of a business’ relevant commercial systems, sales contracts, financial and non-financial records, physical stock and other assets as a means to measure and improve compliance.” WHAT IS POST CLEARANCE AUDIT (PCA)? What pca isn’t! AN ENFORCEMENT TOOL NOT A MEANS OF INVESTIGATING POSSIBLE FRAUD WHERE FRAUD IS SUSPECTED, REFER TO INVESTIGATION SPECIALISTS A FORM OF INTERNAL AUDIT NOT DESIGNED AS A MECHANISM FOR CHECKING CONTROLS CONDUCTED BY CUSTOMS AT THE FRONTIER What are the objectives of PCA? To assure that Customs declarations have been completed in compliance with Customs requirements, via examination of a trader’s systems, accounting records and premises; To verify that the amount of revenue legally due has been identified and paid; To facilitate international trade movements of the compliant trade sector; To ensure goods liable to specific import/export controls are properly declared, including prohibitions and restrictions, licenses, quota, etc.; To ensure conditions relating to specific approvals and authorizations are being observed Benefits derived from PCA Compliant trade facilitated at time of Customs clearance Customs gain better information and understanding of clients’ business Risk levels more easily assessed and reviewed Facilitates client education and comprehensive compliance management focus Customs can promote concept of voluntary compliance and self-assessment Customs administrations’ resources more effectively deployed Suspected fraudulent activities may be identified Provides platform for evaluating entitlement to certain authorisations; e.g. AEO status Types of post-import controls Post-importation transaction verification Port referrals Risk selection Disputed decisions/ importer requests Field / on-site audit Risk selection Office/ desk audit Risk selection Large business focus – special teams Transition from border-focused controls to PCA as the prime basis for Customs controls typically evolves over several years PCA implementation should be embedded in a wider facilitation/modernization context Infrastructure considerations Consider as a first step, post-importation transaction-based controls STEPPING STONES TOWARDS AN EFFECTIVE PCA SYSTEM Process for introducing an effective PCA system Legal and operational framework Strategic Planning Risk Management Relationship with other departments LEGAL and operational framework - Authority and powers of Customs officers Customs laws and regulations should provide the authority to conduct an audit at the premises of the auditee. Necessary powers include the right to: access auditee’s premises; examine business records, business systems, commercial data relevant to Customs declarations; inspect auditee’s premises; uplift and retain documents and business records; inspect and take samples of goods. LEGAL and