Audits
An in-depth, independent look at imports, exports and your internal compliance programme – the way an authority looks at them. You learn where your processes hold, where they fail and what needs to be done.
An audit is worthwhile before the authority arrives – and all the more so once it is already there.
- A group introduces an export compliance programme for the first time
- A customs or foreign trade audit is under way or imminent
- The parent company requires independent evidence
- An application for Authorised Economic Operator (AEO) status is planned
- Customs processes or customs service providers have been reorganised
- Acquisition, integration or new sites
What we audit
Imports and customs
- Tariff classification and its maintenance in the item master data
- Customs value, including freight, ancillary costs, assists and royalties
- Origin and proofs of preferential origin
- Customs procedures, authorisations and simplifications
- Management and monitoring of customs service providers
- Records, traceability and retention
Exports and export control
- Classification of goods, dual-use and catch-all
- Licences and compliance with their conditions
- End-use and end-destination checks
- Sanctions list screening, including ownership and control structures
- Technology transfer within and outside the group
- Export documents and transaction controls
Internal compliance programme
- Policies, work instructions and organisation
- Responsibilities and their formal appointment
- Training and awareness
- Monitoring, internal controls and corrective action
- Intra-group movements of goods between sites
The benchmarks are Union customs law, the Dual-Use Regulation and German foreign trade law, as well as Commission Recommendation (EU) 2019/1318 on internal compliance programmes with its seven core elements and the ICP guidance note of the Federal Office for Economic Affairs and Export Control (BAFA).
How we proceed
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Preparation
Risk analysis across flows of goods, sites and topics. This forms the basis for the audit programme, the sampling concept and the request list.
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System review
We record the organisation and processes at each site and check whether the existing controls are properly designed.
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On-site audit
Interviews with process owners and operational staff. Risk-based samples of import and export transactions at all your sites in Germany and abroad.
Findings with root cause analysis and risk assessment, practical recommendations and support in implementing and steering the measures. You receive:
- List of findings with risk assessment and root cause analysis
- Report for each company and summary for senior management
- Action plan with owners and deadlines
- Closing presentation – on request for reporting to the group
- All documents in German or English
Audits by experienced experts
The audits are carried out by competent and experienced experts with a background in customs and export control. Nothing is delegated to entry-level staff.
Independent follow-up audit
On request, the audit team also supports the implementation, provided nothing stands in the way. A later follow-up audit is carried out by a new team. This keeps the result independent.
Clear procedures for sensitive findings
If an obligation to correct or to report emerges, an escalation procedure agreed in advance applies.
International
We audit sites abroad on site; for foreign law we work with partners in the country concerned.
Frequently asked questions
How long does an audit take?
That depends on the number of sites and the scope. For a company with one site, expect a few weeks; for several sites in Germany and abroad, a few months from preparation to final report.
Does the audit disrupt day-to-day operations?
Hardly. The preparation is based on data and documents, which your team simply provides. On site, we need the process owners for interviews, usually two days per site.
Can you also audit during an ongoing customs audit?
Yes. We compare our findings with the authority's preliminary findings so that corrections can be targeted.
What happens if the audit uncovers a breach?
Whether a correction or disclosure is required follows from the law, not from our report. We agree in advance who will be informed and who decides. Only your company receives the report.
Is there a fixed price?
We usually charge at hourly rates. For a clearly defined audit scope, however, an audit can also be agreed at a fixed price. If the scope is later extended or additional work arises, this is remunerated as agreed in the contract.