HMRC has published CIP (11) 89 highlighting its concerns and its view of the necessary remedial action to resolve the identified problems. The following issues are highlighted in the paper:

  • Make sure you receive the permission to progress message (P2P) and keep a copy on file
  • Make sure your customer has checked if they need an Export Licence – do not guess and enter LIC 99 in Box 44 of the export declaration if you do not know
  • Make sure that you get instructions from your customer in writing to clarify the direct/indirect  representation issue

With the Export Practice Guide also being published, Authorised Economic Operator (AEO) submissions need to reflect procedures that meet these requirements