SAT verification visits can be very intrusive and aggressive. The SAT can visit IMMEX company with Registration in the Certification Scheme, VAT and IEPS (VAT Certification) modality to verify their compliance with their permanent obligations and the circumstances how they obtained the Registration.
As part of the permanent obligations of the VAT Certification, the companies must always allow SAT’s International Trade Certification and International Affairs Administration to the premises and comply with the original requirements.
We know that the authority is currently planning to visit, if not all the companies with registration, then many of them, based on the cases we have learned about so far this year.
This situation should concern the companies, as the authority may determine non-compliance with the Registration following the visit. If non-compliance is determined, the authority will initiate the cancellation process, and the benefits of this certification will be suspended during this process (which could last 4 months).
HOW DOES THE VISIT TAKES PLACE?
1. The authority will contact the company through the contact registered in the digital window (VUCEM), and the company will receive an e-mail with the ACAICE’s supervision visit plan, indicating the visitor’s name, day and time he/she will visit your facilities.
2. The visit plan will outline the time and activity to be carried out. This serves as a basis for the activities and may vary if required by the visitor.
3. At the beginning of the visit, original documents such as the power of attorney of the legal representative, minutes of the current members of the company, identification documents, and other documents will be required.
4. Before the day of the visit, we recommend that you have all the original and digital documents requested ready.
5. The Inventory Control is a key part of the visit. The visitor will dedicate a specific space of his agenda to review the system on the company’s computers, going through each module, and requesting the reports in accordance with the content of section I of Annex 24 of the RGCE.
Based on the Inventory Control information, the visitor will request to see the goods or assets inside your facilities.
6. The visitor will prepare a report summarizing the visit and, if applicable, will record any observations made. When assessing the documentation provided, the Visitor may have additional observations that will not be recorded in the report.
What preventive measures an IMMEX company must take?
- Ensure that the contact information of the legal representative and designated operational liaisons is updated. If the contact person is not updated, plan to do so.
- It is highly advisable to conduct a prior review of compliance with the permanent obligations and requirements to ensure readiness for a possible verification visit.
- Continue planning your visit and consider that it may be extended beyond the scheduled hours.
- Address any observations made by the visitor immediately to prevent them from being recorded in the report. If issues are noted, do not wait for an official notice from the authority; proceed to self-correct and send the evidence physically to the ACAICE offices.
- Seek advice from experts, as failing to address concerns can have serious consequences for the companies.