representatives and Customs officials in the case study countries show that revalidation rather

than complete reapplication is much less burdensome for both parties.

Secondly, there is a low degree of convergence in terms of appeals processes within OIC AEO

programs. Having a formal appeals process is important in terms of voice and accountability.

Voice here is the right to be able to stand upon one’s rights, while accountability refers to the

assumption of responsibility for actions. All international best cases analyzed in Section 2 have

appeals processes in cases of suspension, revocation or cancellation.

Challenge 4- Communication of Customs Authority with private sector and other

government agencies may not be at desirable levels.

Once again AEO programs are voluntary-based and heavily depend on open communication

channels between the Customs Authority and the stakeholders.

Firstly, there seems to be perfect convergence in terms of formal or informal consultations

with industry and stakeholders on AEO program design and implementation as well as

promotion of AEO programs by OIC member Customs. However, it is hard to gauge the degree,

quality and impact of these through survey results only. One should note that insufficient

consultation with the private sector can be challenging as it is possible to cause potential

misconceptions about the anticipated benefits, thereby reducing the incentives for companies

of becoming an AEO.

One particular area where there is need for improvement is the survey of AEO company

satisfaction. Except for Morocco, no country has this feature in their AEO program. It is

important to have regular surveys to collect data on success and challenge factors of the

particular AEO program so that improvements can be devised and applied.

Secondly, communication with other government agencies within OIC AEO programs is low.

Note that the WCO revised the SAFE Framework in June 2015 and recently added Pillar 3,

which identifies specific technical standards to ensure that the AEO program has the support

of other government stakeholders.

Challenge 5- All Customs Authorities choose to use their existing resources for the AEO

design/implementation, which causes scarcity or misallocation of resources.

Table 3.19 shows that none of the OIC AEO programs established new Customs technical

specialty positions for their AEO programs. The transfer of existing personnel to the AEO

design and implementation may cause problems in at least two respects: (i) The transferred

staff may not be endowed with the knowledge and the skills necessary to successfully operate;

(ii) As the numbers of AEO companies increase, there might be a noticeable deficit in qualified

personnel to handle the verification, authorization and post-authorization processes.

Challenge 6- In spite of the number and the diversity of benefits offered in the OIC AEO

programs, these benefits may not be worthwhile to join the program in an economy that

already has many trade facilitation measures in place.

This is one of the main challenges for countries that adopted AEO programs in the aftermath of

other trade facilitating measures in their countries. Therefore, it is important to involve the

private sector during the design phase to pinpoint the needed tangible benefits that can attract

companies to apply for AEO status. Otherwise, the private sector will not show enough interest