Understanding Customs Audits
According to Minister of Finance Regulation No. 125/PMK.04/2007, a customs audit is the examination of financial reports, books, records, and documents that serve as basic evidence of bookkeeping and correspondence relating to business activities. This evidence also includes electronic data and correspondence relating to customs activities and/or inventory of goods in the context of implementing customs laws and regulations.
This inspection is generally carried out on exporters, importers, bonded warehouse operators, temporary warehouse operators, customs service operators, or transportation operators.
In practice, customs audits are generally conducted within three months of the date of the assignment letter. Further details are provided below on how to conduct a customs audit.
- Collection of data related to reports, notes, documents, or books as basic evidence.
- Implementation of field and office work processes.
- Preparation of Audit Working Papers (KKA) by the audit team, as a basis for preparing the Temporary Findings List (DTS)
- DTS is submitted and responded to by the auditee.
- Final discussion – auditee rejects or accepts DTS.
- Preparation of audit report as a basis for determining obligations by the Director General of Customs and Excise or Customs Officials.
Customs Audit Team
Members of the customs audit team are based on their position, rank, and expertise certificates according to their level of assignment. The composition of the customs audit team is as follows.
- Audit Quality Supervisor (PMA) – the highest-ranking position, an auditor with a certificate of expertise as a customs and excise audit quality supervisor. The requirement for PMA is that customs officials must hold a PTA certificate and meet a number of other requirements.
- Technical Audit Controller (PTA) – the second-highest position, an auditor with a certificate of expertise as a technical controller for customs and excise audits. The requirement for PTA status is that the customs official must have served as an audit team leader and meet the existing requirements.
- Chief Auditor – an auditor with a certificate of expertise as a chief auditor of customs and excise. The requirement to become an audit team leader is that the customs official be certified as an auditor and meet the existing requirements.
- Auditor – an employee of the Directorate General of Customs and Excise (DJBC) with a certificate of expertise as an auditor who has the duties, authority and responsibility to carry out customs audits and/or excise audits.
Purpose of Customs Audit
- Testing the level of compliance of customs provisions with customs laws and regulations.
- Prevent potential illegal trading practices.
- Supporting transparency in cross-border business processes.
- Increase state revenue through import duties, export duties and related taxes.
Types of Customs Audits
1. General Audit
A general audit is a customs audit that encompasses a complete and comprehensive examination of compliance with customs obligations. It can be conducted on a planned basis or at any time.
2. Special Audit
A special audit is a customs audit that focuses on compliance with specific customs obligations. For example, a special audit may be conducted in response to an objection to the appointment of a Customs and Excise Officer.
3. Investigative Audit
An investigative audit is a type of customs audit conducted to investigate suspected customs crimes. It is a primary audit and should take precedence over general and special audits.
Scope of Customs Audit
According to Indri Riesfandiari, a lecturer in the Diploma III Customs and Excise study program, the scope of a customs audit encompasses all customs activities conducted on audited objects. These include financial reports, books, records, documents, electronic data, and inventory related to exports, imports, or customs facilities.
Meanwhile, customs activities referred to in this context refer to those carried out during the audit process, such as report review, fieldwork, audits, security, preparation of results, final discussions, and reporting.
Customs Audit Case Example
The case of meat imports by PT Cahaya Sakti Utara Baru (CSUB), which were deemed illegal in 2016, is an example of a customs audit. This case occurred because the importer provided incorrect customs information regarding the type and/or quantity of imported goods and submitted an Import Notification (PIB) with inaccurate data.
Customs officers finally conducted security checks, physical inspections, and laboratory tests on the imported goods. The inspection results indicated that the goods did not match the description stated in the PIB.
This illegal import activity was declared to violate the Regulation of the Minister of Agriculture Number 58/Permentan/PK.210/11/2015 and improper importation violates Law No. 10 of 1995 concerning Customs as amended by Law No. 17 of 2006.
Conclusion
For the Directorate General of Customs and Excise, customs audits are not merely administrative and supervisory obligations, but rather important activities to ensure compliance and create a fair and transparent environment.
For exporting or importing companies, properly conducted and documented audits can minimize the risk of sanctions and enhance the company's credibility with relevant authorities. However, the complexity of regulations and the volume of transaction data often present challenges, especially when performed manually.
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