Compliance
The best defence is a system that holds. More and more obligations attach to goods and their origin – from the supply chain to the carbon footprint. We work with companies to set up processes that function in day-to-day business and stand up to an audit, and we investigate when something has nevertheless gone wrong.
Control systems
- Customs compliance and internal customs organisation
- Internal compliance programme (ICP) for export control
- Tax compliance and internal control system
- Authorised Economic Operator (AEO)
Supply chain and human rights
- Supply Chain Due Diligence Act (Lieferkettensorgfaltspflichtengesetz, LkSG)
- EU Corporate Sustainability Due Diligence Directive (CSDDD)
- Prohibition of products made with forced labour (EU Forced Labour Regulation)
- Conflict minerals
- Risk analysis, supplier screening and complaints procedures
Environment and imports
- Carbon Border Adjustment Mechanism (CBAM)
- EU Deforestation Regulation (EUDR)
- Due diligence statements, evidence and checks by authorities
Training
- In-house training for customs, export and accounting teams
- Conduct during audits and searches
- Instruction of senior management and export control officers
Internal investigations
- Investigation of suspected cases
- Assessment of disclosure and correction obligations
- Coordination with authorities
Anti-money laundering
- Obligations of traders in goods under the Money Laundering Act (Geldwäschegesetz, GwG)
- Risk analysis and know your customer
Frequently asked questions
What does the Supply Chain Act mean for my company?
Larger companies must analyse human rights and environmental risks in their supply chain, take preventive and remedial action, and provide a complaints procedure. Thresholds and obligations are currently changing as a result of the EU Corporate Sustainability Due Diligence Directive – we keep you up to date.
What does CBAM require of importers?
Anyone importing goods such as iron, steel, aluminium, cement, fertilisers or hydrogen into the EU needs authorisation as a CBAM declarant above certain quantities, and must declare the embedded emissions and cover them with certificates. The data for this comes from the supplier – usually the most difficult part.
What does the Deforestation Regulation govern?
Cattle, cocoa, coffee, oil palm, rubber, soya and wood, as well as products made from them, may only be placed on the market or exported if they are deforestation-free and have been produced legally. This must be demonstrated by a due diligence statement including geolocation data; customs checks its reference number at clearance.
What does the EU Forced Labour Regulation change?
From December 2027, products made wholly or partly with forced labour may neither be sold in the EU nor exported from it. Authorities can order their withdrawal and disposal. Those who know their supply chain now will be prepared.
What does a compliance system achieve if things go wrong?
It does more than reduce the risk of errors. A functioning control system can argue against intent and recklessness, has an effect on whether and in what amount a fine is imposed following a voluntary disclosure under foreign trade law, and protects senior management against the allegation of having breached supervisory duties.
Further reading
- AEO: The Authorised Economic Operator
- EUDR: the EU Deforestation Regulation at a glance
- Setting Up a Customs Compliance System in the Company
- CBAM: What importers need to know now