and direction regarding PCA.
POST CLEARANCE
Audit Plan - Scheme/strategy for
AUDIT (GROUP1) audits specifying the objectives,
scope, methodologies and
assignment of auditor/team
members for the audit.
DEFINITION OF TERMS
Desk Audit - An audit conducted at
Trader - An importer, exporter, one
auditors’ premises usually by calling
who engages in transit or the like,
information through correspondence
who has a relationship with
or telephone.
Customs, excluding forwarders, etc.,
who merely convey international On-Site Audit - An audit conducted
cargos, and Customs brokers who at the premises of the auditee.
merely submit declarations on behalf
of the “trader.”
POST CLEARANCE AUDIT
Auditee - An entity selected for an
audit, not limited to importers, as it PCA should not be mistaken for
can include exporters or an "internal audit," which is a
transportation companies, Customs process used to examine and
broker, etc. evaluate internal procedures—either
carried out by a company to assess
Business Sector - Collective term
its own operations or by Customs to
for commercial or industrial
assess its own internal policies and
enterprises usually referred to as the
practices.
Customs’ counterpart (or business
community). While internal audits can serve as
valuable tools for management and
Industry - Group of productive or
play a key role in maintaining
profit-making enterprises.
integrity within an organization, they
Company - Commercial enterprise, are fundamentally different from the
regardless of any relationship with concept of PCA.
Customs.
Stakeholder - One who is involved
OBJECTIVES
in or affected by a course of action.
Verify accuracy of declarations:
Whole Business Transaction - A
value, origin, classification,
business pattern with particular
duties.
commercial / physical distribution of
an import / export cargo, including Ensure compliance with
the payment conditions. import/export controls:
prohibitions, licenses, quotas.
PCA Policy - Statement of an
administration's overall intentions
Check conditions for approvals
and authorizations.
LEGAL AND OPERATIONAL
Facilitate trade for compliant FRAMEWORK FOR PCA
traders.
Legislation must be implemented
to support the effective
application of PCA.
BENEFITS
This legislation should:
Facilitates compliant trade at
Customs clearance; reduces Grant Customs the legal
border controls. authority to perform audits.
Improves Customs’ knowledge Define the rights and
of traders’ businesses. responsibilities of the auditee.
Enhances risk assessment and Customs administrations will draft
identifies system weaknesses. laws and regulations based on:
Supports client education and National
long-term compliance requirements, or
management.
Regional
Ensures more effective frameworks, in the case of a
deployment of Customs Customs union.
resources.
Promotes voluntary compliance
CUSTOMS LAWS AND
and self-assessment.
REGULATIONS
Detects fraudulent activities, IFF,
Conducting PCA should provide the
and TBML for enforcement
following:
action.
Definition of PCA coverage
Evaluates continued entitlement
to Authorized Economic Authority and powers of
Operator (AEO) status. Customs officials/auditors
Penalty scheme
TYPES OF PCA Obligations and rights of
auditees
Comprehensive Audit (Systems-
Based Audit) Right of appeal
Focused Audit (Issue-Based
Audit)
PCA SCOPE AND COVERAGE
Post-Importation Transaction-
Customs laws and regulations
Based Audit (TBA)
must clearly outline the scope
and coverage of PCA. the transaction of the imported
or export goods
They should specify which
individuals or entities can be
audited.
AUTHORITY, POWERS AND
Any business involved in the OBLIGATIONS OF CUSTOMS
following activities may be subject to OFFICERS
audit:
Customs laws must empower
Importing or exporting officers to conduct audits at both
goods auditee and auditor premises.
Receiving goods under
Customs control
Confidentiality obligations must be
Storing such goods enforced to maintain trust with
traders.
Manufacturing goods
subject to Customs supervision
Delivering or distributing Key Powers include:
these goods
Examination of business records
and systems
WHO MAY BE SUBJECT TO AN Retention of documents and
AUDIT? records
Importers/Exporters Inspection of premises
Declarants Sampling of goods
Consignees of imported goods Access to auditee’s premises
Owners or beneficial owners of
the imported goods
OBLIGATIONS AND RIGHTS OF
Subsequent acquirers of the AUDITEES
imported goods
Customs laws must clearly define
Customs clearing agents of the the rights and duties of trade
imported/exported goods participants.
Storage agents of the Obligations:
imported/exported goods
Record-keeping: Maintain
Transporters of the specified records for the legal
imported/exported goods duration tied to duty
claims/refunds.
Other persons/companies
directly or indirectly involved in Accessibility: Provide records
promptly when required. A central team typically manages the
PCA program, with operational units
as needed.
5 RIGHTS OF AUDITEES:
Office locations should enable on-
Appeal site audits (based on geography and
trade volume).
Explanation on Customs value
Some administrations form
Confidentiality of business info
dedicated teams for large
Amend declarations businesses, with trade-sector
specialists (e.g., automotive, textiles,
Goods clearance with security
chemicals) to ensure ongoing
compliance.
OBLIGATION AND RIGHTS OF
AUDITEES
TYPES OF ORGANIZATIONAL
Customs powers must be regularly STRUCTURE
reviewed and updated to meet
CENTRALIZED AUDIT - Structure
national and international
has established a single PCA unit
obligations.
within the administration
Relevant non-Customs laws may
impact PCA, including:
DECENTRALIZED AUDIT- Structure
Commercial, company,
seeks to established several PCA
and tax laws
units within the administration
Import/export licensing
Foreign currency
controls
UN Security Council
obligations (e.g., sanctions, export
controls)
PCA ORGANIZATIONAL
STRUCTURE
PCA interacts with risk management,
enforcement, intelligence, revenue
collection, and legal teams.
Structure must support coordination
and communication across these
areas.
