Compliance Program Checkup: A Checklist for Evaluating Customs Policies and Procedures

Clearing customs is, from a corruption perspective, one of the riskiest things a company can do. Particularly when a business relies on delivering its goods to a country in a timely manner, any delay can become costly. Knowledge of this cost and companies’ need for timely clearance gives corrupt customs officials a tremendous amount of power and can put pressure on company employees or third parties tasked with managing the process. Effective controls in this area are, therefore, a must. With this checklist, companies can assess and monitor the state of their compliance policies and procedures and begin to address any weaknesses. For a deeper dive on this topic, see our three-part series on customs corruption risks: “Identifying the Problem Areas” (Oct. 21, 2015); “Four Ways to Limit the Risks of Working With Customs Brokers, Freight Forwarders and Other Third Parties” (Nov. 4, 2015); and “Should a Company Ever Pay a Facilitation Payment to a Customs Official?” (Nov. 18, 2015).

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