Finland: Both the Managing Authority of the ERDF and the ESF and the intermediate bodies are all public authorities obliged by legislation. The administrative and criminal legislations concern public servants. The exchange of information and contacts between the authorities of the agriculture funds and the judicial authorities has increased as this has been highlighted during the training.

Sweden replied that the eight managing authorities (some administrative some judicial) have regular networking meetings several times a year. They meet to discuss OLAF reporting, take part in COCOLAF meetings and are also part of the SEFI Council headed by the Swedish Economic Crime Agency.

2.REPLIES OF MEMBER STATES

2.1.Revenue

Background information

In 2017, OLAF investigations highlighted large-scale revenue frauds through the undervaluation of goods imported in the EU. Such fraud results in huge losses, not only in customs duties, but also in evaded VAT. OLAF’s investigations underlined that fraudsters will exploit any loopholes and that quantity fraud can pay off. OLAF’s experience shows that undervaluation will remain a threat to be dealt with in the coming years.

To close these loopholes, customs control strategies involving a combination of different controls are pivotal. The customs control strategy should strike the right balance between trade facilitation/simplification and the protection of the EU’s financial interests.

BE 1.1 UNDERVALUATION 1.1 Are you remaining vigilant as regards the risk of undervaluation of goods? ☒YES, fully implementing the recommendation Following the report on the TOR audit on undervaluation in April 2018, a national approach was developed for controls for release for Chapters 61 to 64 having China as country of origin. To this end, five selection profiles (SPS fiches) were created, depending on the degree of undervaluation (<10 %, between 10 and 20 %, between 20 and 30 %, between 30 and 40 %, and between 40 and 50 %). The selections are based on the fair prices that we found in Theseus. In the new selection engine (Seda 2.0 – active since June 2018), extra information can be added to the available fields of the declaration. That information can be used as a selection criterion with the aim of more effective selection. The necessary steps are being taken to use the information regarding the average price in this way so that it can easily be used in the selection lines. In addition, the RIFs relating to textiles and footwear originating from China are followed up in a separate SPS fiche. Here, too, we are preparing to use the fair prices as an extra field in the selection lines. If YES or YES, PARTLY, are you targeting in particular cheap products imported in extremely large quantities, such as textiles and footwear? ☒YES, specifically those goods 1.2 ENHANCEMENT OF CUSTOMS CONTROL 1.2.a Do you have strategies in place that target all types of customs procedure including simplified procedures and all operators taking into account AEOs and other large businesses considered compliant? YES, partly implementing the recommendation. Since the new selection engine ‘Seda 2.0’ was implemented on 20 June 2018, we have been applying an automated deselection logic on the basis of the status and profile of the operator and we use more information in our selection profiles so that we make a more targeted selection (particularly when applying a selection percentage). The main objective of automated deselection is to increase the hit rate and reduce the duplication of identical compliance checks, by reducing the ‘false positives’, with the result that there are also fewer selections which have to be manually refined. Automated deselection takes place chiefly in two phases (status and profile): a) Deselection on the basis of the operator’s status: Operators with the AEO status or the MGO (medium-sized operator) status can be automatically deselected. Within the AEO status, we distinguish between three types of AEO (see reply to Question 1b). The MGO status is explained in Question 1c. It concerns a random deselection in accordance with the selection percentage proposed. b) The operator profile: The profile is made up of compliance (determined on the basis of checks prior to release), conduct in relation to declarations, and the findings in checks other than these prior to release (e.g. audits, investigations). It involves cumulative criteria, meaning that they must all be met in order to be eligible for deselection. It follows from the above that a large compliant operator with a constant supply of goods will be more likely to be deselected than an operator with few consignments. As regards compliance, we look at whether the operator has traded compliantly during the last three months, taking into account the compliance percentage, the number of (non-) compliant items/MRNs and the date of the last check. Compliance is recalculated every night and the three-month time period also shifts forward so that the most up-to-date situation is taken into account. As regards conduct in relation to declarations, we look at whether or not the operator made other similar shipments in the last year and whether this type of shipment is substantial enough to be considered as normal. Since the criteria are cumulative, a flow of goods that deviates from the norm in the case of a compliant operator will therefore not be deselected. These phases run consecutively, i.e. an AEO can enjoy the benefits on the basis of profile, in addition to the benefits on the basis of status. However, which deselection phases are run consecutively is determined by selection profile. It is therefore possible not to apply deselection for certain selection profiles or to apply deselection only on the basis of the status or profile. For instance, no automated deselection is applied for random selections or selections on the basis of AM messages. The system described above is made possible by the quantity of information added to the declaration before it is assessed for the selection profiles. This also allows for this extra information (enhancements) to be used in the selection profiles themselves to make the selection even more targeted. We use it in two ways: - making fewer and more targeted selections by using one or more of the enhancements; - reducing the application of a selection percentage but making a targeted selection of riskier categories. Example: targeting operators who have not been checked in a long time or who display low compliance. Under standard use of a selection percentage, such operators would not be regularly selected, but using this targeted approach, this is not the case. These categories are assessed and adjusted periodically. 1.2.b Did you ensure proper coordination among customs services dealing with risk analysis and controls (central, regional, local services involved in risk analysis and release and post-release departments)? YES, fully implementing the recommendation Pre-release controls: The SPS fiches provide the means of communication between the risk management department and the first-line control services. Over the course of 2018, greater attention was given to providing a clear description of the reason for selection. A new work method was also developed for checking undervaluation, which is referred to in the SPS fiche. Post-release controls/audit: The proposed items for the controls and audits are in part submitted by the risk management department. The proposed items for 2019 are explained in fiches that are available by topic to the control departments. The risk management department also presented it to the departments concerned. 1.2.c Do risk profiles specifically target traditional own resources and provide clear instructions with regard to the type of control to be carried out and risk guidance to the customs release officers? Is risk information shared with other Member States and feedback on the response to this information provided in the EU customs risk management system? YES, partly implementing the recommendation See also Question 1.2.b Since the end of 2018, the tax risk management team has been organised in accordance with the Decision on Financial Risk Criteria (Commission Implementing Decision C(2018) 3293), making it possible to better target the traditional own resources. Significant findings within all risk areas are reported in the CRMS system. 1.2.d Is there close monitoring of the controls results (feedback) which is done in a structured manner to allow effective follow-up and strict implementation of mutual assistance instructions in place? YES, partly implementing the recommendation The feedback for pre-release controls, which is automated, is taken into account by the SEDA 2.0 selection engine (see also Question 1.2.a). The feedback for post-release controls is not automated and is less structured, however, it is included in the development of the data mining models. 1.3 OTHER MEASURES 1.3.a Do you systematically include an automated random element and take into consideration the time-barring three-year period for the communication of customs debt as a risk indicator in the post-release risk analysis? YES, partly implementing the recommendation In order to draw up the proposed items for the post-release controls, we go back 2.5 years to allow sufficient time to carry out the checks within the deadline set. Risk management does not assign ‘random’ items for post-release controls. 1.3.b Do you ensure risk-oriented post-release audits which cover the operator's systems where this is necessary, apply a random element, guide the auditors and take due account of the results of the pre-authorisation stage and of specific standardised checklists? Are the results strictly monitored? NO The proposed items for the post-release audits are in part supplied by the risk management department and are therefore risk-oriented, not random. 1.3.c Are customs controls on operations made by authorised economic operators (AEO) carried out taking account of the risk management performed with respect to the different elements of these operations? YES, fully implementing the recommendation On the basis of the risk assessment in granting or reassessing an AEO permit, a selection percentage is awarded that is used in the selection process within the SEDA 2.0 selection engine. 1.3.d Do national competent authorities make full use of the handbook on operational customs controls based on Member States’ best practices and of the Customs audit guide? YES, fully implementing the recommendation

BG 1.1 UNDERVALUATION 1.1 Are you remaining vigilant as regards the risk of undervaluation of goods? ☒YES, partly implementing the recommendation If YES or YES, PARTLY, are you targeting in particular cheap products imported in extremely large quantities, such as textiles and footwear? ☒YES, specifically those goods Protecting the EU’s financial interests is one of the Customs Agency’s main tasks. In order to prevent attempts to diminish the EU budget and to avoid revenue losses, serious measures are needed to improve the collection of import duties as a traditional own resource of the EU. In this context, coordinated control actions by customs authorities are needed to counter attempted fraud involving under-invoicing. As regards the risk of undervaluation of goods, the administration has created risk profiles focused on checking the declared customs value against specific goods (clothing and footwear) under procedures 40 and 42, country of origin, TR, VN and CN. Risk profiles have been created for certain companies, with particular attention being paid during checks to the declared customs value. 1.2 ENHANCEMENT OF CUSTOMS CONTROLS To fulfil this obligation in the Customs Agency’s draft annual plan for 2019 and to achieve the objective 2. ‘Increasing State budget revenue by effectively preventing and combating customs, currency and excise infringements’, in particular Measure 2.2. ‘Preventing opportunities to evade and avoid taxes and charges by improving legislation, implementing more effective control, strengthening inter-institutional cooperation and coordination and exchanging information effectively’, the Directorate for Customs Activities and Methodology has proposed including the following new tasks in the draft: 1. Reinforced checks on goods being released for free circulation, the documents accompanying them, including additional documents where necessary, checks on goods and taking samples for analysis, with a view to establishing the accuracy of the data declared, in particular the taxation elements in the customs declarations accepted, without prejudice to the application of provisions on administrative penalties; 2. Carrying out documentary checks on the customs declarations accepted, the documents accompanying them, requiring additional documents where appropriate, checking goods and taking samples for analysis or detailed examination in the case of products of CN Chapters 61, 62, 63 and 64 of the EU from China; 3. Using international cooperation to send invoices used to under-declare customs value for checks; 4. Tightening checks on goods that constitute a potential threat as regards the evasion of anti-dumping and/or countervailing duties. Creating indicators for the purposes of risk analysis; 5. The task of establishing unified practice when determining the elements of taxation (tariff classification, origin of goods and customs value) and applying customs exemptions has also been included. 1.2.a Do you have strategies in place that target all types of customs procedure including simplified procedures and all operators taking into account AEOs and other large businesses considered compliant? ☒YES, partly implementing the recommendation A report has been drawn up on the risk of the under-declaration of the customs value of goods, clothing and footwear. Risk profiles are being prepared for certain CN codes (CN Chapters 61, 62, 63, 64) and risk thresholds will be indicated; New functionalities are being created for the purposes of integrating financial risk profiles approved by European Commission decisions. The profiles will be available for use after the publication of guidelines for their integration into national systems; A random selection is being made on the basis of the profiles; The release for free circulation of goods is being analysed at regular intervals and risk profiles are being created with a particular focus: tariff classification, customs value, country of origin, etc.; Reports are being prepared on the control equipment available and recommendations are made with regard to the availability of new resources; 1.2.b Did you ensure proper coordination among customs services dealing with risk analysis and controls (central, regional, local services involved in risk analysis and release and post-release departments)? YES, partly implementing the recommendation Proper coordination has been ensured between all customs units responsible for handling the risk profiles produced and performing the checks required in their operation. Proper coordination has also been ensured between the Customs Agency and other government structures carrying out checks on goods released for free circulation: the National Revenue Agency (NAP), the State Agency for National Security (DANS) and the Directorate General for Combating Organised Crime (GDBOP). 1.2.c Do risk profiles specifically target traditional own resources and provide clear instructions with regard to the type of control to be carried out and risk guidance to the customs release officers? Is risk information shared with other Member States and feedback on the response to this information provided in the EU customs risk management system? YES, partly implementing the recommendation The risk profiles are in particular aimed at preventing the loss of traditional own resources, focusing mainly on checking for the wrong tariff classification, checking the customs value actually declared, verifying the country of origin, and checking that anti-dumping and countervailing duties have not been avoided. The actions to be taken in profiling are clear and described in detail. The instructions in the profiles are specific to the actions to be taken. Where necessary, further coordination takes place between different units. Where irregularities are detected in respect of the above criteria, the information is shared with the other Member States, but only with regard to major seizures or infringements. We currently lack the human resources needed to be able to disseminate this information as effectively as we would like. With regard to information shared by other Member States belonging to the RIF system, it is processed in full, feedback is sent to the originator of a message and, where necessary, there are further contacts to clarify specific details or other additional information. 1.2.d Is there close monitoring of the controls results (feedback) which is done in a structured manner to allow effective follow-up and strict implementation of mutual assistance instructions in place? YES, partly implementing the recommendation Checks based on the risk profiles produced are carried out at regular intervals and, if necessary, additional information is requested or a post-release control carried out. 1.3 OTHER MEASURES 1.3.a Do you systematically include an automated random element and take into consideration the time-barring three-year period for the communication of customs debt as a risk indicator in the post-release risk analysis? YES, fully implementing the recommendation The annual selection of economic operators to be checked is made using an automated process in which 5 % of checks are carried out on operators selected at random. 1.3.b Do you ensure risk-oriented post-release audits which cover the operator's systems where this is necessary, apply a random element, guide the auditors and take due account of the results of the pre-authorisation stage and of specific standardised checklists? Are the results strictly monitored? YES, fully implementing the recommendation Risk-oriented audits under Article 48 of Regulation (EU) No 952/2013 of the European Parliament and of the Council (UCC) are carried out using an automated process for selecting economic operators on the basis of data in customs declarations for a period of 3 years. 5 % of the total number of planned checks is selected at random. Further to the findings of post-release control, the import duties and taxes assessed and other State receivables are entered in the accounts. Administrative proceedings are initiated when infringements are established. 1.3.c Are customs controls on operations made by authorised economic operators (AEO) carried out taking account of the risk management performed with respect to the different elements of these operations? YES, fully implementing the recommendation Automated risk analysis is conducted for all operations, regardless of the role of economic operators in the supply chain. 1.3.d Do national competent authorities make full use of the handbook on operational customs controls based on Member States’ best practices and of the Customs audit guide? YES, fully implementing the recommendation The Customs Audit Guide is used when performing post-release control under Article 48 UCC.

CZ 1.1 UNDERVALUATION 1.1 Are you remaining vigilant as regards the risk of undervaluation of goods? ☒YES, fully implementing the recommendation If YES or YES, PARTLY, are you targeting in particular cheap products imported in extremely large quantities, such as textiles and footwear? ☒YES, specifically those goods In 2018, these strict measures were applied and are still being applied: A) Custom Value Control Strategy in the Czech Republic Director General Order No. 14/2012 Measures on imports of specific textiles and footwear (This Order repealed and replaced Director General Order No. 77/2008) Director General Order No. 14/2012 Measures on imports of specific (i.e. subject to taxes and duties) textiles and footwear came into effect on 12 March 2012. This order describes individual steps to be taken by customs offices in case of a suspicion of undervalued goods import from Southeast Asia. The order defines a procedure following automatically generated risk profiles based on threshold values; these indicate that there is available information on similar goods imports proving a higher than the declared customs value. Article 1 of Director General Order No. 14/2012 is based on the following principle: If there are reasonable doubts based on analytical tools, the documents submitted by the declarant shall be verified by means of international administrative assistance based on the Agreement between the European Community and the Government of the People´s Republic of China on cooperation and mutual administrative assistance in customs matters (OJ L 375, 3 December 2004) or based on agreements on cooperation and mutual assistance with other states. All document checks are performed within the proceedings on the rejection and determination of declared customs value, which is commenced upon the activation of the respective risk profile. Director General Order No. 14/2012 is binding for all customs offices in the Czech Republic. Electronic risk profiles are defined for goods in chapters 42, 52, 54, 55, 56, 58, 59, 60, 61, 62, 63, 64 and 65 of the Common Customs Tariff. (The list of individual subheadings newly contains these as of 1 July 2014, when based on an analysis of specific goods in chapters 61, 62, 63 and 64 the list also contains goods from other chapters.) The Amendment to Director General Order No. 14/2012, i.e. Director General Order No. 16/2015 (Measures on imports of specific textiles and footwear) and the initiative preceding this amendment A meeting of V4 (Visegrád Four) countries on the goods undervaluation took place in Prague in March and April 2015 based on an initiative by the Czech Republic, its objective being the unification of methodology for risk thresholds for the checks of imported textiles and footwear in the V4 countries. The use of OLAF AREP AFIS-AMT tool was agreed on; this tool was examined from the analytical and legal perspective. The V4 countries identified the shortcomings of AREP AFIS-AMT and sent the results to OLAF in April 2015. In the light of the outputs of the Prague meeting as well as of the recommendation by OLAF, another V4 meeting was held in Budapest in June 2015. During these meetings, the Trencin Declaration of the V4 customs administrations was prepared in relation to the introduction of risk profiles with respect to textiles and footwear imported from Asian countries. Risk profiles were defined, the thresholds of which were based on the OLAF AREP AFIS-AMT tool. The Czech Republic is an active member of the OLAF UWG (Undervaluation Working Group), where the Czech delegate informed OLAF about the declaration in September 2015. The Trencin Declaration came into force on 1 Jan. 2016 and in this respect the Director General Order No. 14/2012 was amended by Director General Order No. 116/2015 in the Czech Republic. The risk thresholds were defined to reflect OLAF AREP AFIS-AMT tools. Director General Order No. 116/2015 is binding for all customs offices in the Czech Republic. Methodological information No. 13/2016 Customs Valuation: Comprehensive methodological information No. 13/2016 Customs Valuation effective as of 1 May 2016 has replaced Internal Regulation No. 11/2004 Customs Valuation. The Regulation has been amended mainly with respect to Regulation (EU) No 952/2013 of the European Parliament and of the Council of 9 October 2013 laying down the Union Customs Code. The methodology provides for customs valuation, including indices and procedures related to doubts of a customs office related to the declared customs value. This methodology applies to all goods listed in the Customs Tariff and to all customs offices in the Czech Republic. Methodological information No. 26/2017 Measures on imports of specific textiles and footwear and further specific products (further amendment to Order No. 14/2012) On 2 June 2016 Methodological information No. 26/2017 Measures on imports of specific textiles and footwear and further specific products, which has replaced General Director Order No. 14/2012, came into effect, further stipulating and defining the checks and procedures of customs offices. In line with the methodological information, if there are reasonable doubts based on analytical tools, the documents shall be checked by means of international administrative assistance based on the Agreement between the European Community and the Government of the People´s Republic of China cooperation and mutual administrative assistance in customs matters (OJ L 375, 3 December 2004) or based on agreements on cooperation and mutual assistance with other states. All document checks are performed within the proceedings on the rejection and determination of declared customs value, which is commenced upon the activation of the respective risk profile. Director General Order No. 14/2012 is binding for all customs offices in the Czech Republic. Electronic risk profiles are defined for goods in chapters 42, 52, 54, 55, 56, 58, 59, 60, 61, 62, 63, 64 and 65 of the Common Customs Tariff. This methodology applies to all customs offices in the Czech Republic. B) Threshold Value Systems The basic tool for checking customs values is OLAF AREP AFIS-AMT providing for 120 subheadings from chapters 61, 62 and 64 of the Customs Tariff, which were also provided for by the Trencin Declaration of V4 customs administrations in relation to the introduction of risk profiles for textiles and footwear imported from Asian countries. Subheadings to which the threshold values are applied in the Czech Republic and which exceed the scope of the Trencin Declaration. It is to point out that the Czech Republic broadened the scope of 120 headings covered by the V4 Trencin Declaration and applies the procedures of the Declaration to goods from chapters 42, 52, 54, 55, 56, 58, 59, 60, 61, 62, 63, 64 and 65 too. For the above chapters, the threshold values for the risk profile activation are calculated as at least 50% of the calculated EU fair prices based on the source data by OLAF AREP AFIS-AMT. If the declared value equals or is lower than this threshold a risk profile is activated and all customs offices in the Czech Republic are obliged to follow the procedure stipulated by Methodological information No. 26/2017 Measures on imports of specific textiles and footwear and further specific products. The above procedure is in accordance with the national system to check the declared value applied as of 12 March 2012. As of 1 Jan. 2016, risk thresholds were brought into line with the OLAF AREP AFIS-AMT threshold values, which were also used within JCO SNAKE in 2014. The access to the AMT fair price database was for the Czech Rep. allowed in 2015. National System for Threshold Value Determination: Thresholds in the national system are determined as follows: The declared customs value (it´s unit price) in the SAD (single administrative document) is compared with the unit price of the cleared customs decision for the last 90 days, which represents the middle value of declared import unit prices. The middle value is cleared of extreme values and is calculated from the data on goods imported to the Czech Republic in the period of 3 months prior to the goods import to the Czech Republic in line with trade practice and market conditions. (By 31 Dec. 2017 the goods imports to the EU were reflected, where the data source was Eurostat. Since fair prices from OLAF AREP AFIS-AMT are included in the whole process, the data from Eurostat are no longer used because AREP AFIS-AMT has fully replaced these.) The middle value (median) is thus an objective criterion, since it is the middle value generated from the imports of similar goods to the Czech Republic in the respective period. If the decision uses the term middle value, then it refers to the middle value (median) of unit prices of goods imported to the Czech Republic in the above period of 3 months. The term middle value (median) is well-known, i.e. the value separating the higher half from the lower half of a data sample. The national median calculation is based on the following: For the calculation only data related to the goods released for free circulation (domestic consumption) are used, where the customs value was determined by the means of transfer value in accordance with Art. 70 Regulation (EU) No 952/2013 of the European Parliament and of the Council of 9 October 2013 laying down the Union Customs Code. Data on air and post shipments are not included in the generated data and in case of other means of transport the shipments under 100 kg are not included. With regards to the above declared items of the single administrative document the cases with pending procedure on the questioning of declared customs value are not included. To the above acts is to add that in case of a lawsuit against this national system the courts accepted it in favour of the customs administration. The courts saw the use of the middle value (median) as appropriate and objective. It is not right to decide based on the highest declared customs values to the detriment of the declarant (plaintiff). It is also not right to decide based on the lowest declared customs values in favour of the declarant (plaintiff). C) Confirmation that national measures are appropriate Court procedures in the Czech Republic It was confirmed by the following judgments that national measures against the undervaluation were correct as to the procedural and substantive requirements: • Judgment of the national regional court in Plzeň 57 Af 1/2016-43 - an accusation against the entire system of questioning customs values (the judgment was presented to the representatives of OLAF during the meeting on 26 July 2018) • Judgment of the national regional court in Hradec Králové 52 Af 39/2016 • Judgment of the national regional court in Ústí nad Labem 15 Af 115/2015 from 22 August 2018 established obligation of importer to duly prove price actually paid. The customs valuation procedure was in three cases supported by the national courts and measures taken can be applied in the future successfully. In the Czech Republic has been developed system of customs valuation procedure in line with binding customs legislation and international agreements. With regard to this legitimate approach, the valuation procedure is supported by national courts and it is a crucial point for future work in the field of fight against undervaluation. 1.2 ENHANCEMENT OF CUSTOMS CONTROLS 1.2.a Do you have strategies in place that target all types of customs procedure including simplified procedures and all operators taking into account AEOs and other large businesses considered compliant? YES, fully implementing the recommendation 1.2.b Did you ensure proper coordination among customs services dealing with risk analysis and controls (central, regional, local services involved in risk analysis and release and post-release departments)? YES, fully implementing the recommendation Coordination of activities takes place at two levels. The first level is nationwide and here there is the cooperation of the unit 605 Customs and International Analysis of the department 60 with the units of the department 2; and the second level is regional, at the level of customs offices where there cooperate the dept. 02 Analysis and Information Support of customs offices with department Customs and Controls of the customs offices. Coordination and cooperation takes place through direct and day-to-day contact between the staff of individual departments and also through planned meetings of these departments. At the regional level, the analytical units process, based on a request of departments dealing with post-clearance controls, some analysis, incentives or background material for the preparatory phase of the controls. Within the customs office, there are information transferred between the units which release the goods and the ones who realise the post-clearance controls. These include, for example, handing over of incentives to carry out the control. At the central level, the analysis department also ensures the functionality of the risk analysis application that is used in the preparatory phase of the post-clearance controls. It serves both for the central and the regional units of post-clearance controls. From the results of the carried out post-clearance controls there is processed a bulletin once in three months, which lists the confirmed risks. This bulletin is used on the regional level by the units of post-clearance controls, of analysis and also of the units which release the goods. If one regional unit of post-clearance control identifies and checks some possible risk during a control, for example misclassification, such risk is via the central level of post-clearance control transferred via the bulletin to other regional units of post-clearance control, unit which release the goods or analysis units. 1.2.c Do risk profiles specifically target traditional own resources and provide clear instructions with regard to the type of control to be carried out and risk guidance to the customs release officers? Is risk information shared with other Member States and feedback on the response to this information provided in the EU customs risk management system? YES, fully implementing the recommendation Risk profiles are connected with risk analysis on import or export of risk commodities; they contain specific control instructions for the officers of customs office. This procedure is also applied in the context of cases coordinated by OLAF so called AM messages. Information on newly identified risks is shared with other Member States by registration of such risks into the system RIF. The risks registered in the system RIF are evaluated regularly, and processed into the national systems of risk analysis. 1.2.d Is there close monitoring of the controls results (feedback) which is done in a structured manner to allow effective follow-up and strict implementation of mutual assistance instructions in place? YES, partly implementing the recommendation From the point of view of non-tariff measures, the control and evaluation of the activation of the risk profiles in force are carried out. The results of controls are recorded by the customs offices into electronic records. Methodological unit of post-clearance controls evaluates the results from post-clearance controls which were carried out. Apart from assessment of the individual risk towards other subjects, the results from post-clearance controls are used also for internal training activities with the aim to improve the procedures. The results of the post-clearance audits (also the conditions of the permit are checked) are transmitted to the relevant departments, which use them for example for re-assessment of the conditions. The results of the post-clearance controls are also regularly evaluated, for example in 2018 there were finished 449 post-clearance controls, from which almost 87 % identified breaching of regulations. 1.3 OTHER MEASURES 1.3.a Do you systematically include an automated random element and take into consideration the time-barring three-year period for the communication of customs debt as a risk indicator in the post-release risk analysis? YES, partly implementing the recommendation Within post-clearance controls the automated random element is not included. Before the post-clearance controls are carried out there is the preparation phase within which the risk is identified in relation to the particular customs declaration resp. a specific subject. This is a situation where the risk is identified and the subjects are sought, or the other way round, the subject is identified and the risk is sought, which would be subsequently verified. The choice of subjects and risks is carried out both at the customs offices and at the methodical unit. If the risk is identified by the methodological unit, such information is transferred to customs offices as an incentive to carry out the control or as so called thematic focus. If a new risk is identified and confirmed at the customs office (verified within the control), it is subsequently evaluated by the methodological unit in relation with other subjects. Then, within the preparatory phase, there is used the application for risk assessment (AVR). This application identifies risks at an individual subject, and the risks are possible to be verified within the control, for example in relation to tariff classification or the customs value. The time limit for notification on customs debt is one of the piece of data which are taken into account within the preparatory phase, in relation to the fact whether it is possible to carry out the post-clearance control and notify about the customs debt within the set time limit. Within methodological unit the length of how long a post-clearance control lasts evaluated twice a year, with respect to the 3 years' time limit for the notification of customs debt. 1.3.b Do you ensure risk-oriented post-release audits which cover the operator's systems where this is necessary, apply a random element, guide the auditors and take due account of the results of the pre-authorisation stage and of specific standardised checklists? Are the results strictly monitored? YES, partly implementing the recommendation Yes, we provide post-clearance audits concentrated on declarant systems. The random element is not applied; post-clearance audits are preferably performed at those subjects where the risks are identified. Within post-clearance audits, among other things, there are taken into account the results of audits before the permission was granted, and whether the conditions are still met. During the post-clearance audits the control lists are used. The results of post-clearance audits carried out are transferred to the relevant departments for further use, for example re-assessment of conditions. The results of carried out post-clearance audits are evaluated by the methodological unit and then used in internal training to improve the performance of further audits. 1.3.c Are customs controls on operations made by authorised economic operators (AEO) carried out taking account of the risk management performed with respect to the different elements of these operations? YES, fully implementing the recommendation 1.3.d Do national competent authorities make full use of the handbook on operational customs controls based on Member States’ best practices and of the Customs audit guide? YES, fully implementing the recommendation

DK 1.1 UNDERVALUATION 1.1 Are you remaining vigilant as regards the risk of undervaluation of goods? ☒YES, fully implementing the recommendation The Danish Customs Authority: In 2018, the inspection topic of under-invoicing generally continued to be an important and prominent focus area for the Danish Customs Authority, which must be able to match and optimise analysis methods/tools in relation to risk information on irregularities and patterns of fraud received at any given time. Thus, data from a range of sources — mainly declaration information in the customs system — are used in connection with risk analyses conducted by the Danish Customs Authority’s Financial Customs Analysis Unit. The data are analysed in the Business Intelligence (BI) and Tableau IT systems. An advantage of Tableau is its effectiveness in visually representing trends and irregularities in import patterns, and the fact that it is operated in cooperation with OLAF. If YES or YES, PARTLY, are you targeting in particular cheap products imported in extremely large quantities, such as textiles and footwear? ☒YES, specifically those goods The Danish Customs Authority: In an attempt to prevent Denmark being used as a country of entry for goods declared at very low values, the Danish Customs Authority’s analysis units have established risk profiles in the electronic risk analysis system in order to detect consignments/goods with obvious signs of under-invoicing. Risk profiles and physical checks are intended to put a stop as early as possible to repeated declarations of under-invoiced goods, where necessary by requesting a security as a condition for release. Profiles were created, among other things, for products under textile Chapters 61 and 62, as well as for footwear under Chapter 64 originating from China. Precisely such goods were involved in the earlier cases in both Denmark and the rest of the EU. 1.2 ENHANCEMENT OF CUSTOMS CONTROLS 1.2.a Do you have strategies in place that target all types of customs procedure including simplified procedures and all operators taking into account AEOs and other large businesses considered compliant? YES, fully implementing the recommendation The Danish Customs Authority: The Danish Customs Authority sets priorities for the annual operation on the basis of an assessment of materiality and risk, using the resources available for the operation. The priorities are also based on the collection and management of the customs duties that constitute the EU’s own resources. The general aim of the operational strategy is to ensure effective risk-based customs controls designed to detect fraud and irregularities involving imports from third countries. 1.2.b Did you ensure proper coordination among customs services dealing with risk analysis and controls (central, regional, local services involved in risk analysis and release and post-release departments)? YES, fully implementing the recommendation The Danish Customs Authority: Risk analysis carried out in the Customs Authority’s Financial Customs Analysis Unit focused on the legal movement of goods in respect of financial customs duties. It was agreed, among other things, that significant control results should be passed on by physical and post-clearance control units to the Financial Customs Analysis Unit in order to optimise future risk analyses. 1.2.c Do risk profiles specifically target traditional own resources and provide clear instructions with regard to the type of control to be carried out and risk guidance to the customs release officers? Is risk information shared with other Member States and feedback on the response to this information provided in the EU customs risk management system? YES, fully implementing the recommendation The Danish Customs Authority: The Financial Customs Analysis Unit receives risk information (RIF) on new trends concerning possible areas of fraud from the Commission or other EU customs authorities via the EU communication system (CRMS). The unit assesses all the RIFs. Where necessary, financial RIFs will lead to the establishment of risk profiles in the import system, with the profile indicating clearly which type of control is to be carried out. The Customs Authority uses the CRMS to share risk information with other Member States. 1.2.d Is there close monitoring of the controls results (feedback) which is done in a structured manner to allow effective follow-up and strict implementation of mutual assistance instructions in place? YES, fully implementing the recommendation See point 1.2.b. 3 OTHER MEASURES 1.3.a Do you systematically include an automated random element and take into consideration the time-barring three-year period for the communication of customs debt as a risk indicator in the post-release risk analysis? YES, fully implementing the recommendation The Danish Customs Authority: When carrying out controls, the Customs Authority applies a statistical element to the control selection, and also focuses on the three-year time-barring period. 1.3.b Do you ensure risk-oriented post-release audits which cover the operator's systems where this is necessary, apply a random element, guide the auditors and take due account of the results of the pre-authorisation stage and of specific standardised checklists? Are the results strictly monitored? The Danish Customs Agency cannot answer, as the question is unclear for us. 1.3.c Are customs controls on operations made by authorised economic operators (AEO) carried out taking account of the risk management performed with respect to the different elements of these operations? YES, fully implementing the recommendation The Danish Customs Authority: Companies with AEO authorisation will also be monitored on the basis of materiality and risk, although to a lesser extent on account of their AEO status. 1.3.d Do national competent authorities make full use of the handbook on operational customs controls based on Member States’ best practices and of the Customs audit guide? YES, fully implementing the recommendation

DE 1.1 UNDERVALUATION 1.1 Are you remaining vigilant as regards the risk of undervaluation of goods? ☒YES, fully implementing the recommendation If YES or YES, PARTLY, are you targeting in particular cheap products imported in extremely large quantities, such as textiles and footwear? ☒YES, specifically those goods. 1.2 ENHANCEMENT OF CUSTOMS CONTROLS 1.2.a Do you have strategies in place that target all types of customs procedure including simplified procedures and all operators taking into account AEOs and other large businesses considered compliant? YES, fully implementing the recommendation 1.2.b Did you ensure proper coordination among customs services dealing with risk analysis and controls (central, regional, local services involved in risk analysis and release and post-release departments)? YES, fully implementing the recommendation 1.2.c Do risk profiles specifically target traditional own resources and provide clear instructions with regard to the type of control to be carried out and risk guidance to the customs release officers? Is risk information shared with other Member States and feedback on the response to this information provided in the EU customs risk management system? ☐YES, fully implementing the recommendation 1.2.d Is there close monitoring of the controls results (feedback) which is done in a structured manner to allow effective follow-up and strict implementation of mutual assistance instructions in place? YES, fully implementing the recommendation 1.3 OTHER MEASURES 1.3.a Do you systematically include an automated random element and take into consideration the time-barring three-year period for the communication of customs debt as a risk indicator in the post-release risk analysis? YES, partly implementing the recommendation 1.3.b Do you ensure risk-oriented post-release audits which cover the operator's systems where this is necessary, apply a random element, guide the auditors and take due account of the results of the pre-authorisation stage and of specific standardised checklists? Are the results strictly monitored? YES, fully implementing the recommendation 1.3.c Are customs controls on operations made by authorised economic operators (AEO) carried out taking account of the risk management performed with respect to the different elements of these operations? YES, fully implementing the recommendation 1.3.d Do national competent authorities make full use of the handbook on operational customs controls based on Member States’ best practices and of the Customs audit guide? YES, fully implementing the recommendation

EE 1.1 UNDERVALUATION 1.1 Are you remaining vigilant as regards the risk of undervaluation of goods? ☒YES, partly implementing the recommendation In 2018 Estonia paid a lot of attention to the goods the declared value of which was below the normal value (either EE internal or from EU databases). In addition to the criteria implemented by COM and delivered via the TARIC database (measures of type 430 and 431), Estonia also used many national criteria. At the end of 2018, a criterion was created which specifically targets the goods which are declared significantly under the EU fair price. The reason for the late introduction of this criterion by EE was the outdated data of the EU database AMT (data was 2 years old and not updated). The criterion created at the end of 2018 (taken into use in January 2019 due to technical reasons) works on the data of the Theseus database. If YES or YES, PARTLY, are you targeting in particular cheap products imported in extremely large quantities, such as textiles and footwear? ☒YES, but targeting also other goods Estonia continues to apply all the national minimum price profiles to all goods from the nomenclature. Moreover, increased attention is paid to and checks are carried out on ALL the goods under COM actions 430 and 431. The new criterion introduced in 2018 takes into account all the goods which come from China and Vietnam belonging to Chapters 61-64, irrespective of the quantity and consignee of the goods. 1.2 ENHANCEMENT OF CUSTOMS CONTROLS 1.2.a Do you have strategies in place that target all types of customs procedure including simplified procedures and all operators taking into account AEOs and other large businesses considered compliant? ☒YES, partly implementing the recommendation Most of attention is given to the procedures which are used to declare the goods for release into free circulation (IM40 and IM42), because the percentage of the other procedures is very small in Estonia. COM measure 430 applies to all procedures. The declared value of goods is checked to the same extent in respect of all declarants/consignees with no distinction between AEOs and non-AEOs. 1.2.b Did you ensure proper coordination among customs services dealing with risk analysis and controls (central, regional, local services involved in risk analysis and release and post-release departments)? ☒YES, fully implementing the recommendation In Estonia the entire customs service is on the so-called central level. We have very close cooperation among the customs officials in the areas of risk analysis and control (risk analysis - Intelligence Department, customs control - Customs control officers (Customs Department) and tax auditors (Audit Department) carrying out post-clearance audit). Twice a year the so-called customs valuation round tables take place with the participation of the officials from the departments engaged in the field (intelligence/risk, customs control, policy, legal, post-release audit), where we share information, give guidance and take decisions on difficult (extraordinary) cases. When the Intelligence department spots a risk, they consult the Customs Department (customs value, classification, origin) and the Tax Audit Department. As a result of such cooperation, it is decided whether the declaration/goods are to be directed to supplementary checks in the course of customs clearance and/or subsequent verification (post-clearance control). Please provide any useful detail to explain the actions undertaken in 2018 and why the recommendation have been partially implemented or not implemented. 1.2.c Do risk profiles specifically target traditional own resources and provide clear instructions with regard to the type of control to be carried out and risk guidance to the customs release officers? Is risk information shared with other Member States and feedback on the response to this information provided in the EU customs risk management system? YES, partly implementing the recommendation Customs checks in Estonia are focused on goods, irrespective of the incurrence and amount of duties and taxes (customs duty, VAT, excise duty) applicable to the goods or the status of the consignee/declarant. The relevant instructions have been made available to officials through internal guidelines and correspondence. In addition, an official responsible for creating a criterion also provides relevant instructions of practise (annex to the criterion). For example: Criterion no 9175: the criterion applies to the control of goods’ statistical value. Verification whether the goods’ statistical value is correctly indicated (calculated) and comparison of the goods’ declared price per kg (EUR) with the average EU price per kg. Please see the tables of average prices under profile 636 in the RIHO database. Please describe the control actions in the CTMS (Control Task Management System) notebook. Taking into account the new circumstances revealed, direct the declaration to the red, green channel. Check/control even if the consignor/consignee and/or declarant is AEO. In case of further questions, contact the expert in the customs value. RIF – data exchange is carried out systematically between Estonia and other Member States. In 2018 Estonia drew up 63 RIFs, one of them on undervaluation. 1.2.d Is there close monitoring of the controls results (feedback) which is done in a structured manner to allow effective follow-up and strict implementation of mutual assistance instructions in place? YES, fully implementing the recommendation The Intelligence Department and the Customs Department are regularly monitoring the efficiency of selectivity/risk criteria, and on the basis of monitoring results they make a decision: either to change or remove a criterion, or to send the object to subsequent verification, or apply the criterion to the same extent as before. 1.3 OTHER MEASURES 1.3.a Do you systematically include an automated random element and take into consideration the time-barring three-year period for the communication of customs debt as a risk indicator in the post-release risk analysis? YES, fully implementing the recommendation Estonia carries out random checks regularly. In those cases the declarations have been selected randomly for physical check of the goods or/and documents. As a result of such controls in most cases no major errors (mistakes) are detected. 1.3.b Do you ensure risk-oriented post-release audits which cover the operator's systems where this is necessary, apply a random element, guide the auditors and take due account of the results of the pre-authorisation stage and of specific standardised checklists? Are the results strictly monitored? YES, partly implementing the recommendation All the objects directed to the Tax Audit Department in 2018 had been selected on the basis of risk analysis and sent to post-clearance controls due to their risk. Estonian companies are, in many cases, relatively small and therefore the performance of post-clearance audit (where also internal control systems are audited) does not bring any additional effect. All post-clearance audits in Estonia are classified as “Other kinds of post-clearance controls”. As a general rule, in case of all post–clearance controls we request documentary evidence which should prove that the transactions have been entered into accounts and corresponding payments have been made. In other words, post-clearance controls are not limited to supplementary documents of customs declarations, accounting is checked as well. In Estonia there is a national manual for performing controls, called “Tax Auditor’s Operating Procedure. 1.3.c Are customs controls on operations made by authorised economic operators (AEO) carried out taking account of the risk management performed with respect to the different elements of these operations? YES, partly implementing the recommendation When a risk criterion applies, the declared value of the goods is verified, which is a uniform procedure, no matter whether the declarant/consignee is AEO or not. Accordingly, companies holding an AEO status and lodging declarations in their own name and on behalf of another person (debtors jointly and severally) are controlled on the same grounds as other companies. 1.3.d Do national competent authorities make full use of the handbook on operational customs controls based on Member States’ best practices and of the Customs audit guide? NO Estonia has its own national guidelines for the verification of customs value and determination of a new customs value. Likewise, there is a national manual in Estonia for carrying out controls: “Tax Auditor’s Operating Procedure”. Sometimes we use Customs Audit Guide to get ideas.

IE 1.1 UNDERVALUATION 1.1 Are you remaining vigilant as regards the risk of undervaluation of goods? ☒YES, fully implementing the recommendation DG Budget expressed concern over undervaluation of products from China as to whether the EU’s customs controls protect its financial interests and whether the Commission and the Member States have designed robust import procedures that protect those interests. They identified serious weaknesses indicating that there are shortcomings such as ineffective implementation of customs controls on imports and this adversely affects the financial interests of the EU. In this regard, and with a view to the customs audit in 2019 which will address undervaluation, Customs Risk Management Unit commenced targeted operations in 2018 to tackle undervaluation. A series of risk operations were mounted using the Automated Monitoring Tool set by OLAF as a guide to values declared. If YES or YES, PARTLY, are you targeting in particular cheap products imported in extremely large quantities, such as textiles and footwear? ☒YES, specifically those goods As stated in 1.1 above, footwear and textiles were considered to be grossly undervalued coming into the EU from China. Therefore a number of targeted risk operations were mounted to specifically address this issue and verify the values declared for consignments of Chapters 61 - 64. 1.2 ENHANCEMENT OF CUSTOMS CONTROLS 1.2.a Do you have strategies in place that target all types of customs procedure including simplified procedures and all operators taking into account AEOs and other large businesses considered compliant? YES, fully implementing the recommendation Risk profiles are in place to target imports to safeguard the financial interests of the Union, among other interests. One of these considered risks is non-compliance with customs procedures. In this regard risk profiles regularly target import consignments for documentary checks to verify if importers are complying with their obligations. AEO status is a trade facilitation measure granted on the basis that a business/entity has met standards in relation to safety & security, financial solvency and compliance with customs rules. Therefore priority treatment in customs checks is a benefit of AEO status. Similarly simplified procedures are granted on the bases of a clean record of customs compliance. In this regard, risk profiles only target a % of AEOs. Customs Division in Ireland have a centralised Compliance and Post Clearance Unit which oversees a national compliance and post clearance programme for our Customs Customer Case base, including AEO and those authorised for Simplifications. From a post clearance perspective our Customs Audit and Post Clearance Check targets include a provision that a specific percentage of the cases or declarations chosen must be authorised traders. 1.2.b Did you ensure proper coordination among customs services dealing with risk analysis and controls (central, regional, local services involved in risk analysis and release and post-release departments)? YES, fully implementing the recommendation The National Risk Analysis Unit is a centrally operated unit. Risk profiles are set in consultation with the various stakeholders in the EU, Revenue and other Government Agencies to ensure protection of our EU and national borders. These profiles are monitored for effectiveness and are updated according to EU Regulations or intelligence received. From a post clearance and compliance perspective Customs Division oversees and coordinates our compliance and post clearance programs. This includes support, guidance on best practice and advice on legislation. Customs Division also chairs a post clearance and a control officer group which consists of all our post clearance and compliance personnel and provides a central forum for discussing relevant issues around this aspect. 1.2.c Do risk profiles specifically target traditional own resources and provide clear instructions with regard to the type of control to be carried out and risk guidance to the customs release officers? Is risk information shared with other Member States and feedback on the response to this information provided in the EU customs risk management system? YES, fully implementing the recommendation Risk profiles cover all aspects of customs risk, including fiscal risk. Our categories of financial risk include origin, valuation, classification, anti-dumping, quota & customs procedures which are considered to affect the financial budget. Each profile is specifically designed to target any of the above either at the point of importation or at the trader’s premises. Clear concise instructions are given to the control officer carrying out the check. Any irregularities are addressed and if necessary shared among other Member States via our RIF system (Risk Information Forms) which requires feedback from each. 1.2.d Is there close monitoring of the controls results (feedback) which is done in a structured manner to allow effective follow-up and strict implementation of mutual assistance instructions in place? YES, fully implementing the recommendation Control results are regularly monitored and any irregularities identified which would constitute infringements are dealt with locally by the control officer. Any irregularities or fraudulent activity detected is reported to our Investigation & Prosecution Division. 1.3 OTHER MEASURES 1.3.a Do you systematically include an automated random element and take into consideration the time-barring three-year period for the communication of customs debt as a risk indicator in the post-release risk analysis? N/a 1.3.b Do you ensure risk-oriented post-release audits which cover the operator's systems where this is necessary, apply a random element, guide the auditors and take due account of the results of the pre-authorisation stage and of specific standardised checklists? Are the results strictly monitored? YES, fully implementing the recommendation Ireland’s Customs Division oversees a national Compliance and Post Clearance Interventions planning policy in accordance with identified priorities with relevant monitoring and controls in place, utilising available risk analysis and risk assessment tools. Our Customs post clearance interventions are based on risk analysis, using automated data processing techniques, with the purpose of identifying and mitigating the risks. This is an overall strategy which incorporates all aspects of risks identified and/or signalled through various channels including results from pre-authorisation stage. We have produced a national customs audit and control guide that encompasses standard checklists to assist our officers in carrying out their post clearance roles. We also incorporate a random element to our post clearance programme to compliment the electronic risk analysis aspect. Customs Division in Ireland work closely with our Regional Control Officers and Customs Audit personnel on all aspects of Customs Control to provide support, advice and guidance. All our Divisional structures have responsibility for putting in place a risk-based programme for customs post clearance controls around the customs economic activity taking place within their remit. All results from this programme are monitored closely and our rules, procedures and processes updated as required. 1.3.c Are customs controls on operations made by authorised economic operators (AEO) carried out taking account of the risk management performed with respect to the different elements of these operations? YES, fully implementing the recommendation A.E.O. status and their treatment by customs is set out in 1.2.a above. AEOs are subject to the same rules and regulations as all other importers but do not come under the same level of customs controls as their status is based on mutual transparency, correctness, fairness and responsibility. However from a Compliance perspective each AEO in Ireland is monitored within the first 12 months of being granted such an authorisation and at least every three years after that. In addition, our compliance programme ensures that relevant information is available and assessed on an on-going basis in order to provide early signals of any issues with such traders. 1.3.d Do national competent authorities make full use of the handbook on operational customs controls based on Member States’ best practices and of the Customs audit guide? YES, fully implementing the recommendation A customs audit is the examination of accounts and business records to verify the compliance of the importer with their obligations with relevant legislation and Revenue requirements. Revenue operates a presumption of honesty that all customs declarations submitted contain the correct information. Therefore it is necessary to validate a selection of declarations by post release checks and audit to confirm compliance. These audits are conducted in line with the EU Customs Audit Guide which sets out the requirements of conducting the audit. From a Post Clearance perspective our National Customs Audit Guide takes primary guidance from the EU Customs Audit Guide. On our Compliance side the EU guidance documents are an integral part of our control program formulation

EL 1.1 UNDERVALUATION 1.1 Are you remaining vigilant as regards the risk of undervaluation of goods? ☒YES, fully implementing the recommendation Risks in the area of customs valuation remain high on the agenda. Risk profiles have been created to indicate declarations for either physical or documentary controls. There is a systematic risk assessment and continuous feedback for risk profiling. Greece participated in the joint customs operations organized by OLAF. In addition, two national operations were conducted in 2018 to combat underpricing in textiles and footwear originating from China. If YES or YES, PARTLY, are you targeting in particular cheap products imported in extremely large quantities, such as textiles and footwear? ☒YES, but targeting also other goods Apart from targeted risk profiles for particularly cheap products imported in extremely large quantities, such as textiles and footwear, in the context of AMs, RIFs and other information sources, risk profiles have been created in order to point out declarations for either physical or documentary control also for products, other than textiles and shoes, e.g. ceramics, table ware and kitchen ware etc. 1.2 ENHANCEMENT OF CUSTOMS CONTROLS 1.2.a Do you have strategies in place that target all types of customs procedure including simplified procedures and all operators taking into account AEOs and other large businesses considered compliant? YES, fully implementing the recommendation The strategic objectives of the Independent Authority for Public Revenue and the operational objectives of the General Directorate of Customs and Excise Duties include the fight against tax evasion and smuggling. In this context, targets are set centrally for customs controls, for all types of customs procedures, for all operators, without excluding the holders of simplified procedures and AEOs. 1.2.b Did you ensure proper coordination among customs services dealing with risk analysis and controls (central, regional, local services involved in risk analysis and release and post-release departments)? YES, partly implementing the recommendation An operational plan is drawn up in order to achieve the objectives set for the controls indicated and conducted on the basis of a risk analysis (central or local) by all the above mentioned services. Measures taken to improve co-ordination and increase audit effectiveness include workshops and meetings on specialized control issues and information use. Coordination between the customs services involved in the risk analysis is adequate and constantly improving. 1.2.c Do risk profiles specifically target traditional own resources and provide clear instructions with regard to the type of control to be carried out and risk guidance to the customs release officers? Is risk information shared with other Member States and feedback on the response to this information provided in the EU customs risk management system? YES, partly implementing the recommendation All risk profiles, including those relating to traditional own resources, refer to clear guidelines and guidance on the type of control and provide risk information to those responsible for control at the customs clearance stage. Risk information is shared with other Member States and feedback is provided to a satisfactory degree. 1.2.d Is there close monitoring of the controls results (feedback) which is done in a structured manner to allow effective follow-up and strict implementation of mutual assistance instructions in place? YES, partly implementing the recommendation The full content of the instructions and guidelines provided to the Member States with the AM messages of OLAF is without any delay notified to all customs authorities. The results of the post clearance controls which may be conducted in compliance with the recommendations of each particular AM message are provided by the competent control authorities upon request. There is also the possibility to identify from the records kept by the Directorate of Electronic Governance of the Independent Authority for Public Revenue the results of the controls indicated by the activation of the risk profile/s which was/were created according to the content of the AM recommendations. Additionally, the further stages of assessment and recovery of the customs debt that may be incurred, as well as the possible judicial evolution of the cases, is monitored in the framework of the management of the AM case files. 1.3 OTHER MEASURES 1.3.a Do you systematically include an automated random element and take into consideration the time-barring three-year period for the communication of customs debt as a risk indicator in the post-release risk analysis? NO The three-year period for the communication of the customs debt is taken into account by the competent customs authorities, when local risk analysis is carried out. The Customs Information System is not currently designed to indicate random checks in the context of post-release risk analysis in an automated manner; however, the function is in the process of being redesigned. 1.3.b Do you ensure risk-oriented post-release audits which cover the operator's systems where this is necessary, apply a random element, guide the auditors and take due account of the results of the pre-authorisation stage and of specific standardised checklists? Are the results strictly monitored? YES, partly implementing the recommendation Post release audits are carried out on the basis of a non-automated “local” risk analysis by the competent authorities. 1.3.c Are customs controls on operations made by authorised economic operators (AEO) carried out taking account of the risk management performed with respect to the different elements of these operations? YES, fully implementing the recommendation Customs controls carried out on operations made by AEO take into account risk analysis and apply on all the different elements of these operations. (The answer is given with caution, because of the unclear -to us- wording of the question). 1.3.d Do national competent authorities make full use of the handbook on operational customs controls based on Member States’ best practices and of the Customs audit guide? ☐NO A key tool for carrying out post clearance audits, according to the instructions provided, is the Customs Audit Guide which has been translated into Greek and is available to the competent customs authorities to assist with their audit work.

ES 1.1 UNDERVALUATION 1.1 Are you remaining vigilant as regards the risk of undervaluation of goods? ☒YES, fully implementing the recommendation Risk profiles are kept. Analyses carried out by OLAF reveal a limited incidence of the current undervaluing of imports in Spain. If YES or YES, PARTLY, are you targeting in particular cheap products imported in extremely large quantities, such as textiles and footwear? ☒YES, specifically those goods Textiles, footwear, handbags and pound shop articles are the main products affected by risk profiles. 1.2 ENHANCEMENT OF CUSTOMS CONTROLS 1.2.a Do you have strategies in place that target all types of customs procedure including simplified procedures and all operators taking into account AEOs and other large businesses considered compliant? YES, fully implementing the recommendation Risk profiles can work on any customs procedure and on any kind of operators. 1.2.b Did you ensure proper coordination among customs services dealing with risk analysis and controls (central, regional, local services involved in risk analysis and release and post-release departments)? YES, fully implementing the recommendation There is a central unit that designs the risk profiles and coordinates all control activities, which are carried out at a regional level. 1.2.c Do risk profiles specifically target traditional own resources and provide clear instructions with regard to the type of control to be carried out and risk guidance to the customs release officers? Is risk information shared with other Member States and feedback on the response to this information provided in the EU customs risk management system? YES, fully implementing the recommendation There are clear instructions about the actions to perform once the declaration has been selected for its control. RIF is used to inform other Member States; for instance, in case goods are returned to origin, if someone tried to dispatch them in another Member State. An analysis of all information received from other Member States is carried out. 1.2.d Is there close monitoring of the controls results (feedback) which is done in a structured manner to allow effective follow-up and strict implementation of mutual assistance instructions in place? YES, fully implementing the recommendation The central unit performs the proper follow-up. 1.3 OTHER MEASURES 1.3.a Do you systematically include an automated random element and take into consideration the time-barring three-year period for the communication of customs debt as a risk indicator in the post-release risk analysis? YES, fully implementing the recommendation The expiration date is always taken into account in the risk analysis process carried out in ex-post controls. 1.3.b Do you ensure risk-oriented post-release audits which cover the operator's systems where this is necessary, apply a random element, guide the auditors and take due account of the results of the pre-authorisation stage and of specific standardised checklists? Are the results strictly monitored? YES, partly implementing the recommendation There is not a proper index of tests to be performed in every ex-post control. On the contrary, each actuary decides how to perform the control. However, audits are revised by the superior, who may decide to perform additional actions. In any case, the Commission´s Guide is at disposal of the actuaries. Also, the company records can usually be accessed and all previous information is taken into account, including the information provided in the previous custom authorizations, if there were any. 1.3.c Are customs controls on operations made by authorised economic operators (AEO) carried out taking account of the risk management performed with respect to the different elements of these operations? YES, fully implementing the recommendation AEOs are subject to customs controls. However, they might be adapted to their risk level. 1.3.d Do national competent authorities make full use of the handbook on operational customs controls based on Member States’ best practices and of the Customs audit guide? YES, fully implementing the recommendation They are available to the actuaries who perform the controls.

FR 1.1 UNDERVALUATION 1.1 Are you remaining vigilant as regards the risk of undervaluation of goods? ☒YES, fully implementing the recommendation For several years, the inspection services of the DGDDI [General Directorate of Customs and Excise] has made it a priority to combat customs valuation fraud. The background note distributed each year to set the priorities for the following year has made tackling customs valuation fraud one of the key points of its inspection actions for 2018. The fight against undervaluation is therefore a priority for all the customs services. A specific instruction was circulated to the services in 2018 to reinforce the role played by checks carried out at the time of clearance in combating undervaluation. The new instruction is accompanied by several summary factsheets to facilitate the work of the inspection services. The factsheets cover the following points: – the legal basis for valuation set out in the UCC and Implementing Regulation (EU) 2015/2447 of 24 November 2015; – the performance of ex-ante checks with regard to valuation. This factsheet was prepared on the basis, in particular, of the European inspection guide entitled ‘Handbook on Operational Controls’; – the arrangements for implementing the guarantees provided for in Article 244 of Implementing Regulation (EU) 2015/2447 of 24 November 2015. This factsheet sets out the strict cumulative conditions under which a guarantee may be taken (existence of a strong suspicion of undervaluation, existence of a sudden, massive and suspicious flow, the guarantee must be the only way to stop the flow). These specific conditions are intended to ensure that guarantees are not systematically set up at the slightest suspicion. The factsheet also indicates alternative methods for determining value. The purpose of this factsheet is to enable the inspection services to act autonomously and respond rapidly. Guarantees have already been put in place successfully by the DGDDI, but each time the intervention of the General Directorate was required. Valuation fraud is also dealt with in ex-post checks. This is because of the difficulty in rapidly obtaining the documents needed to establish whether the declared price reflected the transaction value of the goods. During the ex-ante checks the invoice sent may be false and may correspond exactly to the very low price declared. The ex post checks also serve to identify cases of valuation fraud resulting from the failure to include the elements of value specified in Article 71 of the Union Customs Code (UCC). If YES or YES, PARTLY, are you targeting in particular cheap products imported in extremely large quantities, such as textiles and footwear? ☒YES, but targeting also other goods These goods are targeted, but not these goods alone. For example, measures 430 and 431 are taken into account. They do not only concern chapters 61 to 64 of the Customs Tariff. The DGDDI also conducted a data-mining experiment in 2018 in the National Risk Analysis and Targeting Department (Service national d’analyse de risque et de ciblage - SARC). The two cases of usage tested concern: – identification of undervaluation through a statistical analysis of the value/mass ratio. The method employed is to carry out a statistical study of the distribution of value/mass ratios for a product. This approach makes it possible to identify atypical values that may need to be checked more thoroughly. Once the risk has been confirmed by the analysts, the results obtained may give rise to an ex-post check or the creation of selection profiles in customs clearance applications;, – the study of express freight fraud using a flow chart visualisation tool. The tool put in place makes it possible to observe the distribution of these flows in time, their distribution in space (concentration of imports in specific areas or even at specific addresses), and the links between consignors/consignees/destination addresses, in order to identify atypical schemes that require ex-post checks or the creation of selection profiles. 1.2 ENHANCEMENT OF CUSTOMS CONTROL 1.2.a Do you have strategies in place that target all types of customs procedure including simplified procedures and all operators taking into account AEOs and other large businesses considered compliant? YES, fully implementing the recommendation The DGDDI has a control strategy based on a risk analysis and the implementation of three types of checks, depending on the challenges identified: ex-ante checks are conducted at the time of clearance, ex-post 1 checks (other types of ex-post checks) are conducted up to 4 months after clearance, and ex-post 2 checks (ex-post audits) are implemented until the expiry of the period concerned). Checks are performed on all operators and procedures after a risk analysis has been conducted and the targeting and/or programming of checks has been established. For simplified procedures, the ex-ante targeting of the checks is done at the stage of the Initial Simplified Declaration. The other clearance procedures introduced by the UCC are not used, or are only occasionally used, in France. Thus, only two procedures have been issued for registration in the declarant’s records: one for export and one for import for goods not subject to customs duties. Special procedures are also checked. Generally speaking, in addition to the risk linked to the goods themselves, the risk arising from the reliability of the operator is also taken into account. The National Risk Analysis Grid (GRINAR) is used to determine the risk level for almost 2 000 operators for import and export flows. This grid makes it possible to direct the checks. The AEO deemed to be reliable are not excluded from targeting during checks. However, in line with the UCC, in the case of certain ex-ante controls, fewer checks are carried out on these AEO. A reduction of the control rate is provided for in Article 24(1) of the DA and concerns the two authorisations (AEO-C and AEO-S) based on the type of check carried out by the customs authority. The selection profiles therefore apply to them. 1.2.b Did you ensure proper coordination among customs services dealing with risk analysis and controls (central, regional, local services involved in risk analysis and release and post-release departments)? YES, fully implementing the recommendation As part of the ‘Customs 2018’ project, the General Directorate for Customs and Excise decided to introduce an integrated chain of checks to tackle the new challenges relating to safety, security and combating fraud. This decision was taken in the context of the increasing move towards paperless procedures for the flow of declarations and also the implementation of the new Union Customs Code (UCC). In order to rationalise the chain of controls, the control policy has been made more integrated and consistent, and risk analyses have been centralised in a single service in order to improve the quality of targeting and of the control instructions. The creation of a national Risk Analysis and Targeting Department (SARC) was ratified by an order of 29 February 2016. The decision to centralise in a single service the risk analyses in the areas for which it has responsibility (pre-clearance – safety/security, clearance and taxation) was taken in order to better target customs checks to make them more efficient. This centralisation makes it possible to: – have better expertise and improve the control guidelines; – bring together the information needed for the analyses at a single point; – avoid duplication; – monitor and analyse the results in order to adapt the control guidelines; – introduce more consistent arrangements and obtain better results in legal proceedings; – optimise the implementation of data mining. The SARC is therefore responsible for all risk analyses and operational studies, particularly those which concern clearance. It thus has a monopoly on creating national selection profiles (PRONAT) in the RMS (declarations targeting tool) and in planning ex-post checks. On the basis of the SARC’s risk analyses and the national control guidelines, the Inspection Information and Steering Units (Cellules de renseignement et de pilotage des contrôles – CRPC) guide and coordinate the checks in cooperation with the regional supervisor or the supervisors at the investigation offices and services. The CRPC were set up in 2018 by reorganising the Units for Information and Planning of Inspections (Cellules de renseignement et d’orientation des contrôles – CROC). The CRPC sets out the work objectives for the year and the control priorities. It ensures that the programming of the checks takes account of the priorities established in coordination with the other services of the Directorate. The CRPC is the regional service in charge of steering all the checks and monitoring their efficiency. It follows up the regional control guidelines and draws up the review of the regional action plans. The CRPC is the linchpin of all the regional services responsible for conducting checks and following up legal proceedings. It uses the steering tools at its disposal to ensure the effectiveness of the measures adopted and suggests the adaptations needed to improve results. Lastly, it ensures that the programming of the controls is effectively implemented. 1.2.c Do risk profiles specifically target traditional own resources and provide clear instructions with regard to the type of control to be carried out and risk guidance to the customs release officers? Is risk information shared with other Member States and feedback on the response to this information provided in the EU customs risk management system? YES, fully implementing the recommendation The DGDDI’S targeting engine groups together all the selection profiles used by the services in charge of targeting (SARC at national level, the Inspection Information and Steering Units (CRPC) at regional level and the supervisor at the level of the customs offices). Each profile contains a description explaining the reason for the profile, the type of fraud being investigated and the action to be taken. The services are informed each month of the RIF messages sent by the other Member States. Generally speaking, the quality of the RIF sent by the other Member States does not always allow a return. Moreover, very few RIF messages are sent by France. The MA cases sent by OLAF concerning traditional own resources are given specific treatment by the SARC. The fraud mechanism described is studied and the French traffic analysed. The SARC sets up one or more dedicated profiles and gives precise instructions to the services concerning the action to be taken. 1.2.d Is there close monitoring of the controls results (feedback) which is done in a structured manner to allow effective follow-up and strict implementation of mutual assistance instructions in place? YES, fully implementing the recommendation The implementation of the provisions of Regulation 517/97 by the DGDDI is detailed in an instruction to the services which was circulated in January 2015 (Note 1500032). This document was endorsed by the EU authorities. After 3 years’ experience of implementation and, above all, the creation of the SARC, it became necessary to update this document, mainly in order to improve the treatment of MA cases. A new instruction, issued by the JCF2 office of the General Directorate in cooperation with office JCF3, SARC and the National Directorate for Customs Information and Investigations (DNRED), was sent to the customs services by a note of May 2018. The circuit for handling MA cases concerning the protection of the Union’s financial interests (PFI) is as follows: 1. Receipt of the MA cases by the SARC and the General Directorate; 2. The SARC’s PFI team investigates the case in cooperation with the offices of the General Directorate; 3. Establishment of the selection profiles in the RMS targeting tool; 4. Circulation of control instruction to the services using an Investigation and Control Suggestion Sheet (SDEC – Suggestion d’enquête et de contrôle). 5. Implementation of the checks by the DNRED’s Directorate for Customs Investigations (DED) or the Regional Investigation Departments (SRE) and the customs offices via the CRPC, on the basis of the risk analysis with input by the SARC; 6. Transmission to the SARC of the information and the results of the control and investigation services responsible for MA cases relating to PFI for transmission to office JCF2; 7. Transmission of the information and results of the checks to OLAF. Specifically, when an MA case concerning the protection of the EU’s financial interests is sent by OLAF by AFIS mail, it is received by SARC and the General Directorate. It is immediately studied so that one or several selection profiles can be set up as quickly as possible. The case is then subjected to extensive analysis by SARC’s PFI group so that input and specific details can be added for France. An Investigation and Control Suggestion Sheet (SDEC) is drawn up by the SARC. This sheet details the case, the analysis of the case and the input added. It also specifies the action to be taken by the control services. The sheet is submitted to the General Directorate for validation before it is circulated to the service. The results of checks are sent by the services to the SARC, which draws up a table for monitoring the cases. This table is sent each quarter by the JCF2 office to OLAF via AFIS Mail. 1.3 OTHER MEASURES 1.3.a Do you systematically include an automated random element and take into consideration the time-barring three-year period for the communication of customs debt as a risk indicator in the post-release risk analysis? YES, fully implementing the recommendation With regard to the checks made at the time of clearance, an automated random selection of the declarations is set up. With regard to ex-post 1 checks, a schedule is implemented on the basis of the general guidelines set by the CRPC. The head of the customs office, in coordination with the supervisor, draws up a timetable for performance of the checks.This schedule takes into account the reliability of the operators. Priority is given to scheduling the weakest operators (managing sensitive traffic and/or procedures). However, the service ensures that it performs checks at least once every three years on operators that are subject to few checks during that period. 1.3.b Do you ensure risk-oriented post-release audits which cover the operator's systems where this is necessary, apply a random element, guide the auditors and take due account of the results of the pre-authorisation stage and of specific standardised checklists? Are the results strictly monitored? YES, fully implementing the recommendation Post-release audits are called ex-post 2 checks (contrôles ex-post 2) or investigations (enquêtes) in France. Ex-post 2 checks are conducted in a hierarchical manner: 1. Depending on the requests for checks by SARC as part of its investigative responsibilities; 2. At the initiative of the CRPC in liaison with the Regional Guideline Directives; 3. At the initiative of the investigative services. The evaluation sheets drawn up are always accompanied by explanations concerning the fraud investigated and the action to be taken by the services. In mutual assistance cases, a specific SDEC (Investigation and Control Suggestions and Guidance) sheet specifies, following input from a national traffic analysis, the investigations to be carried out following MA cases for example. In this case too, investigations are based on risk and instructions are given to the investigators. The results of the checks are incorporated in the SILCF (Anti-fraud information system). They can be consulted by all the services responsible for risk analysis and targeting. However, random selection is not part of the ex-post 2 check selection mechanisms. In France all investigations are based on programming. Programming is usually reinforced by the increase in importance of the SARC and of the programming operated by the CRPC at local level, which must ultimately lead to a reduction in the proportion of own-initiative investigations. 1.3.c Are customs controls on operations made by authorised economic operators (AEO) carried out taking account of the risk management performed with respect to the different elements of these operations? YES, fully implementing the recommendation The AEO are considered to be trustworthy operators in the context of the customs operations they perform. As such, in accordance with EU rules, they have specific customs benefits. Operators certified as AEO have differentiated and privileged treatment. In addition to personalised monitoring and advice, the AEO enjoy benefits with regard to checks. A reduction of the control rate is provided for in Article 24(1) of the DA and concerns the two authorisations (AEO-C and AEO-S) based on the type of check carried out by the customs authority. The AEO-C, in particular, have the benefit of fewer ex-ante checks (apart from checks relating to the CAP, health checks or checks concerning standards), depending on the operator’s risk level. AEOs benefit from fewer checks only in cases of declarations submitted by an AEO on its own account or by an AEO representing another AEO. Control counters in the clearance system allow screen-based supervisors to respect the requirement to perform fewer checks and not to make unnecessary checks of declarations. Apart from these cases where fewer checks are performed, the AEO are treated like other operators. The same selection profiles are used for them where these profiles are not based on an EORI (Economic Operator Registration and Identification number) and all the data in the declaration can be targeted. 1.3.d Do national competent authorities make full use of the handbook on operational customs controls based on Member States’ best practices and of the Customs audit guide? YES, fully implementing the recommendation These guides are not used directly by the services. However, practice in the DGDDI’s services is in line with the indications in these guides. The instructions in these guides are reiterated or used when specific instructions are sent to the services. This was the case, for example, in 2018 with regard to the performance of ex-ante checks of customs value. (See Question 1.1)

HR 1.1 UNDERVALUATION 1.1 Are you remaining vigilant as regards the risk of undervaluation of goods? ☒YES, fully implementing the recommendation If YES or YES, PARTLY, are you targeting in particular cheap products imported in extremely large quantities, such as textiles and footwear? ☒YES, but targeting also other goods 1.2 ENHANCEMENT OF CUSTOMS CONTROLS 1.2.a Do you have strategies in place that target all types of customs procedure including simplified procedures and all operators taking into account AEOs and other large businesses considered compliant? YES, fully implementing the recommendation 1.2.b Did you ensure proper coordination among customs services dealing with risk analysis and controls (central, regional, local services involved in risk analysis and release and post-release departments)? YES, fully implementing the recommendation 1.2.c Do risk profiles specifically target traditional own resources and provide clear instructions with regard to the type of control to be carried out and risk guidance to the customs release officers? Is risk information shared with other Member States and feedback on the response to this information provided in the EU customs risk management system? YES, fully implementing the recommendation 1.2.d Is there close monitoring of the controls results (feedback) which is done in a structured manner to allow effective follow-up and strict implementation of mutual assistance instructions in place? YES, fully implementing the recommendation 1.3 OTHER MEASURES 1.3.a Do you systematically include an automated random element and take into consideration the time-barring three-year period for the communication of customs debt as a risk indicator in the post-release risk analysis? YES, fully implementing the recommendation 1.3.b Do you ensure risk-oriented post-release audits which cover the operator's systems where this is necessary, apply a random element, guide the auditors and take due account of the results of the pre-authorisation stage and of specific standardised checklists? Are the results strictly monitored? YES, fully implementing the recommendation 1.3.c Are customs controls on operations made by authorised economic operators (AEO) carried out taking account of the risk management performed with respect to the different elements of these operations? YES, fully implementing the recommendation 1.3.d Do national competent authorities make full use of the handbook on operational customs controls based on Member States’ best practices and of the Customs audit guide? YES, fully implementing the recommendation

IT 1.1 UNDERVALUATION 1.1 Are you remaining vigilant as regards the risk of undervaluation of goods? ☒YES, fully implementing the recommendation Following the recommendation 1, in 2018 we have expanded our methodologies to fight against undervaluation, including the “Fair prices methodology”. Particularly, we have included in our system risk profiles based on goods that are systematically undervalued, as they are detected by THESEUS, a statistical data-mining tool provided by JRC. Through this tool, we prioritize the flows of goods to be checked on the basis of the highest estimate of the taxable base loss. Once selected the flows of goods to be controlled, we use two methodologies: - “Fair price methodology” to target documentary checks, where the percentage of control depends on impact analysis - “Italian credibility methodology” to target the physical check at the time of Customs clearance, 100% percentage of control. The “Risk Threshold Value” used in the “Fair Price Methodology” is the 50% of Fair Price (statistical value/net mass) related to 8 digits code and country of origin as reported in THESEUS. We update the rate of controls on the basis of results of controls. The “Risk Threshold Value” used in the “Credibility Methodology” is based on percentiles and quartiles of unit values (statistical value/net mass or statistical value/supplementary unit) applied to TARIC 10 digits code, grouping the countries of origin as reported in THESEUS- Cluster of Prices Panel. We update the thresholds on the basis of results of controls. If YES or YES, PARTLY, are you targeting in particular cheap products imported in extremely large quantities, such as textiles and footwear? ☒YES, but targeting also other goods Our reference to choose the goods to be checked is THESEUS – Systematic Undervaluation Panel, Among them, there are also textiles and footwear, imported in small or large quantities. Particularly, we target the nature of transaction 11, to exclude small sampling of textiles and footwear. 1.2 ENHANCEMENT OF CUSTOMS CONTROLS 1.2.a Do you have strategies in place that target all types of customs procedure including simplified procedures and all operators taking into account AEOs and other large businesses considered compliant? YES, fully implementing the recommendation Italian Customs control System allowed us to create risk indicators taking in account each box of the SAD, for this reason we can target all types of customs procedure and managing the rate of control according to the compliance of the operator (AEO or NO AEO). 1.2.b Did you ensure proper coordination among customs services dealing with risk analysis and controls (central, regional, local services involved in risk