100

Cancellation of the AEO Status

The certificate is cancelled in the following situations:

Discovery that the certificate is given based on false or incomplete information or

falsified documents.

Members of the Board of Directors, shareholders holding more than 10 percent of the

capital or persons authorized to represent the company in Customs and foreign trade

transactions are sentenced by a final judicial decision on serious criminal offenses or

serious financial crimes that violated public safety.

Use of rights and privileges covered by the certificate as well as special type seals on

behalf of another person.

If the certificate is cancelled, all rights and privileges related to the certificate are also

revoked. Firms whose AEO certificates have been cancelled cannot apply for the

certificate for 3 years following the cancellation.

4.2.5. Overview of the AEO Program

4.2.5.1. Challenges

Technology

The AEO implementation is a fast-developing area due to improvements in information and

communication technologies. Adaptation of new technologies requires the government to

respond immediately in order to prevent additional problems or difficulties that would emerge

otherwise.

Large volumes of data are collected by the government from the AEOs, which create added

safety and security concerns on the side of the government.

It is natural to expect that the other government bodies have access to this data to prevent

double-entry by the companies. There is some degree of cooperation between the Ministry of

Trade and the Ministry of Transport and Infrastructure in terms of data sharing related to the

AEOs.

Private Sector

Expectations of private companies from the AEO program vary in accordance with their

conception of the system.

Many companies are of the view that the application procedure takes a long time, there are

many detailed criteria to comply with but there are no standards, sector-specific measures to

be taken. Evaluation process is subject to the perception of different experts in the

headquarters of Customs administration.

As most of the AEO holders were previous Type-A ATS certificate holders, they did not observe

any further benefits of the AEO program such as the use of priority lines or reduced

guarantees.

One misunderstanding on the part of private companies was that they were expecting to be

exempted from submitting to Customs product-specific documents such as licenses,