Controls
This chapter outlines the internal control environment that supports customs and excise compliance at terminal level. It distinguishes between three interrelated layers of control: operational internal controls, general compliance controls, and license compliance controls. Together, these ensure that all relevant activities are performed in accordance with legal requirements, license conditions, and internal standards.

Operational Internal Controls
Operational controls govern the accurate and consistent execution of customs- and excise-related activities in the terminal's day-to-day operations. These include: 

 

 

 Accurate registration of product movements  in the Terminal Management System (TMS), capturing relevant data such as product classification, quantity, and regulatory status (e.g. customs warehoused, excise suspended). 

 

 

 Automated interfacing between TMS and the Customs Management System (CMS) , enabling timely and correct generation of customs declarations, EMCS messages, and related compliance records. 

 

 

 Segregation of duties  between planning, execution, and reporting roles to minimise operational and compliance risks. 

 

 

 Routine checks and reconciliations , exception reporting, and automated monitoring supported by the BzCtrl compliance platform to identify and address deviations. 

 

 

 These controls help ensure the operational integrity and traceability of customs- and excise-relevant processes. 

 The following section provides an overview of the key controls that form part of the Customs and Excise Compliance Framework. These controls are designed to manage legal obligations, mitigate compliance risks, and ensure the integrity of customs- and excise-related processes across operational, general compliance, and license-specific areas. 

 It is important to note that the design, scope, and frequency of these controls are not static. They are subject to change based on regulatory developments , business needs , operational changes , and findings from audits or monitoring activities . As such, the control framework is adaptive by nature and reviewed on a regular basis to ensure that it remains effective, proportionate to risk, and aligned with the evolving requirements of the business and the applicable legal landscape. 

 

 

 

 

 

 

 

 

 

 

 Control: Monitoring and Clearance of Outgoing Customs Documents 

 

 

 

 

 In accordance with applicable customs and excise regulations, the consignor bears fiscal responsibility for ensuring the timely and accurate clearance of outgoing customs documents, including but not limited to transit (e.g. T1), electronic Administrative Documents (e-ADs), and export declarations . 

 The purpose of this control is to monitor the clearance status of such documents , identify any delays or irregularities, and take timely corrective action where needed. This helps to ensure that all obligations related to the closure of the customs procedure are met and that the organisation remains protected against potential financial liabilities , such as duties, penalties, or guarantees being called upon due to unclosed movements. 

 By safeguarding the proper clearance of outgoing customs flows, this control contributes to the organisation's overall customs compliance, risk mitigation, and audit readiness. 

 

 

 

 

 

 

 Control: Incident Review and Trend Analysis 

 

 

 

 

 

 

 The objective of this control is to periodically review recorded incidents within the customs and excise compliance domain in order to identify recurring patterns, root causes, or structural weaknesses . This review is conducted both at a macro level  to detect trends or systemic issues that may require corrective or preventive measures and at a micro level , where individual incidents may warrant more detailed investigation. 

 By systematically analysing incident data, this control supports continuous improvement , risk mitigation , and the strengthening of internal controls , ensuring that appropriate follow-up actions are taken and that lessons learned are embedded in the organisation's compliance practices. 

 

 

 

 

 

 

 

 

 Control: Monthly Stock Reconciliation 

 

 

 

 

 

 

 

 

 This control ensures that a monthly reconciliation of stock records is performed to verify that all goods held in the terminal are properly accounted for in the administrative systems. The objective is to confirm the accuracy, completeness, and consistency of physical stock levels against system-based inventory records. 

 From a compliance perspective, customs and excise authorities require businesses operating under suspension or bonded regimes to maintain adequate and reliable stock records as part of their record-keeping obligations. Regular reconciliation supports this requirement and helps detect discrepancies, losses, or administrative errors in a timely manner. 

 This control is fundamental to maintaining the integrity of inventory data , safeguarding authorisation conditions, and ensuring ongoing compliance with customs and excise legislation.

General Compliance Controls
General compliance controls are preventive and governance-focused, ensuring that activities at the terminal are legally permissible and that responsibilities are properly mandated. These include: 

 

 

 Product acceptance controls , designed to confirm that only goods falling within the authorised scope of the terminal's customs and excise licenses are accepted for storage, processing, or movement. This includes verification of product type, regulatory classification, and handling requirements during onboarding or order entry. 

 

 

 Validation of mandates and powers of attorney , ensuring that all parties represented in customs and excise transactions (e.g. importers, exporters, consignors) have issued valid, legally binding authorisations. These documents are reviewed for correctness, signed by authorised representatives, and maintained as part of the compliance documentation set. 

 

 

 Review of contractual terms , including Incoterms and service agreements, to clarify roles and responsibilities in customs declarations and excise obligations. 

 

 

 These controls serve as a first line of compliance assurance, preventing unauthorised or non-compliant activities before execution. 

 It is important to note that the  design, scope, and frequency  of these controls are not static. They are subject to change based on  regulatory developments ,  business needs ,  operational changes , and  findings from audits or monitoring activities . As such, the control framework is  adaptive by nature  and reviewed on a regular basis to ensure that it remains effective, proportionate to risk, and aligned with the evolving requirements of the business and the applicable legal landscape. 

 

 

 

 Control: Annual Verification of Valid Mandates 

 

 This control ensures that all customer mandates, such as powers of attorney and authorisations for customs representation, are reviewed annually to confirm their validity, scope, and legal effectiveness . The aim is to ensure that, wherever possible, the customer remains the party directly liable towards the customs authorities, thereby reducing the organisation's financial and operational risk. 

 Given that such mandates are often time-limited and critical to determining responsibility in customs matters, this control supports a consistent and documented approach to managing representation. It ensures that declarations are made on a proper legal basis and that any exceptions are justified, assessed, and approved within an established risk framework.

License Compliance Controls
License compliance controls ensure that the terminal continues to meet the conditions of its customs and excise authorisations. Key elements include: 

 

 

 Monitoring of license conditions , such as permitted activities, approved goods, bonded storage limits, and site layout specifications. 

 

 

 Change management procedures   to assess the impact of legal, operational, or structural changes on license scope or validity (e.g. changes in legal entity role, board composition, or site infrastructure). 

 

 

 Maintenance and periodic review of the AO/IC   (Administrative Organisation and Internal Control), which forms the basis for demonstrating compliance with license requirements. 

 

 

 Filing of required notifications and reports   with authorities, including periodic customs declarations, EMCS movements, and inventory statements. 

 

 

 Internal audits and control testing , supported by the BzCtrl platform, to identify compliance gaps, monitor corrective actions, and document continuous improvement. 

 

 

 By integrating these three layers of control, the terminal ensures a comprehensive and proactive approach to customs and excise compliance supporting operational accuracy, legal accountability, and regulatory assurance. 

 

 It is important to note that the   design, scope, and frequency   of these controls are not static. They are subject to change based on   regulatory developments ,   business needs ,   operational changes , and   findings from audits or monitoring activities . As such, the control framework is   adaptive by nature   and reviewed on a regular basis to ensure that it remains effective, proportionate to risk, and aligned with the evolving requirements of the business and the applicable legal landscape.

Learning
A key element of maintaining an effective Customs and Excise Compliance Framework is ensuring that all relevant stakeholders possess an up-to-date understanding of applicable legislation, procedures, and industry practices. Within the BzCtrl. platform, a dedicated Learning module supports this objective by offering structured access to various sources of knowledge, including: 
 
 Industry-provided learnings , such as regulatory insights, practical case studies, and peer experiences 
 
 
 Learnings issued by the European Commission , including updates to Union Customs Code (UCC) guidance, explanatory notes, and implementation practices 
 
 These resources are essential in equipping personnel with the awareness and insight required to make informed decisions, interpret obligations accurately, and anticipate regulatory changes. By embedding learning into the compliance framework, the organisation fosters a culture of continuous improvement , reinforces individual accountability , and strengthens its ability to remain compliant in a dynamic and complex regulatory environment . 1. UCC Learning Program  2. Other learnings made available by the European Commission 3. General Trade 4. Learning content provided by the European industry association FETSA