As outlined in previous member notices the Australian Border Force (ABF) have advised under the updated Australian Customs Notice No. 2023/23 that the mandatory CPD module is now available for completion.
Members are reminded that ALL licensed customs brokers must complete this mandatory module by 31 March 2024 which is ONLY available via the Department's ABF Australian Trusted Trader (ATT) training portal.
In response to member feedback concerning "due diligence" within the mandatory module, Freight & Trade Alliance (FTA) has sought clarification on the following statement:
As part of their due diligence requirements, licensed customs brokers must also take reasonable steps to verify the identity of their clients for the purposes of the Act; which would also be highly beneficial for their own commercial interests.
The ABF considers 'reasonable steps' will, at minimum, include obtaining and retaining photo ID for the client, verifying a clients representative is linked to the company they purport to be representing and verifying the client has an appropriate email address.
In response to FTA, the ABF has provide additional advice:
A licensed custom broker has always been required to undertake due diligence to ensure all information provided to the ABF is true and correct, including the identity of the importer.
Taking reasonable steps to identify the client will vary depending on the type of client, terms of trade, client relationship etc. and business processes should reflect this. In certain situations this requirement is best met via photo identification, however, and in the case of a multinational corporation, a customs broker can meet the due diligence requirements by other means such as liaising with the company directly to ensure the representative does in fact act for the company.
Additional information on due diligence requirements will be provided to Industry as part of the review of customs broker licence conditions.
FTA / APSA will continue its advocacy lead and importantly, will ensure that customs brokers remain at the forefront of all emerging reforms.
Sal Milici - Licensed Customs Broker
General Manager Trade Policy & Operations - FTA / APSA