2.II.1. General provisions

In order for customs authorities to determine that the applicant has a high level of control over its operations and the flow of goods, through a management system for commercial records and, where applicable, transport records, which allows for the correct execution of customs controls, the applicant must meet all the requirements established in Article 25 of the AE CAU.

The following general conditions must be taken into account with regard to the verification of this particular criterion:

• It must be verified in relation to all of the applicant's customs activities.
• Customs authorities must use all available information and knowledge regarding authorizations previously issued to the applicant. In general, if the previous audit was carried out recently and no changes have occurred since then, this part of the applicant's activity will not need to be re-verified. In any case, it must be ensured that the various aspects and conditions have been considered in this prior audit.
• It is recommended that part of the verification be carried out on-site, during visits to the company in question.
• When conducting the audit at the applicant's premises, several key elements must be considered:
  • Verification that the information provided in the application and other documents is correct and that the routines and procedures described by the applicant are documented and applied in practice;
  • Testing operations to ensure that an audit trail exists in the records;
  • Checking that the IT system used is reasonably protected against intrusion and manipulation and that historical events are recorded in the system so that changes can be tracked if necessary.

When verifying the specific requirements listed in Article 25(1) of the CAU, customs authorities must always take into account the specific nature and commercial activity of the operator, while also taking into account several common considerations.