Recently, Customs notified hundreds of importers regarding the imminent start of an audit of the alleged inconsistency between the statements made when applying for the grant of the Sworn Advance Import Declaration (DJAI) and the final import Declaration.
These audits would be related to a complaint made by the recently suspended Customs Administrator. In the complaint it is stated that thousands of companies had used the previous DJAIs regime to convert foreign currency abroad in excess of what was actually due. Specifically, for the importers artificially increased the amount of imports or re-used the same DJAI several times or did not subsequently make imports, all in order to convert excess foreign exchange abroad.
The purpose of the audit is to detect inconsistencies in the documentation of foreign trade between 2012 and 2015, which could lead to criminal investigations for money laundering, criminal breach of exchange law and criminal tax law and contraband.
We recommend that companies properly prepare for such audits. To this end it would be appropriate to begin reviewing the documentation of imports made between 2012 and 2015 to identify potential inconsistencies between DJAIs and subsequent import shipments. It would also be advisable to contact the bank currency tracking to see if they have past operations that have not closed.
