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A company that has obtained AEO status has also completed a self-assessment. The basis of this self-assessment lies in the company’s own procedures and internal control measures. Furthermore, the company’s manager has declared that after the issuance of the authorisation, the company will, on their own initiative, report any changes and will regularly determine whether the AEO requirements are still being met – in other words, "I will monitor."
The question is whether companies are aware of the requirements in this regard and whether they are acting accordingly. In practice, the reality is often challenging. Only a limited group of companies has measures or a control framework in place within which procedures related to customs and AEO can be implemented.
However, monitoring is not a voluntary activity but a requirement. It must be part of the company’s own internal control system, and the AEO must be able to demonstrate that and how the controls were performed. It is also important that the results of monitoring are recorded and can be presented.
Internal controls, internal audits, and an external audit are by no means a luxury to establish whether the company is "in control." Are the controller or managing director fully and timely informed by everyone about changes in the AO/IC (Administrative Organisation/Internal Control)? Or about incidents in customs formalities or safety incidents? Have the procedures ever been updated or reviewed for actual implementation or execution?
These are all relevant questions in the context of maintaining AEO, and the time has come to adopt an integrated and structured approach. An approach that should result in an AEO Control Framework, where various measures ensure that the AEO remains “in control.”