15 May 2003

Six-Month Review of AMPS

On Friday, May 9 the CSCB was represented at the official kick-off to the previously announced six-month review of AMPS. During the Minister of National Revenue’s round table discussion of the review, it was learned that CCRA intends to have its review completed by early fall 2003. Key associations such as the CSCB will play an important role in this review that will include both national and regional consultations. The stated purpose of the review is to assess whether the original goals of AMPS have been or will be met with the program’s current design. It is the intention of CCRA to continue modifying the program throughout the review as areas for improvement are identified rather than waiting until the final report is filed.

Among the issues initially highlighted for review are the following:

- some penalty amounts are too large
- penalty amount vs. value of goods
- “whichever is greater” penalties
- innocent mistakes and clerical errors
- high volume transactions
- materiality of infractions
- uncertainty over corrections
- allocation of penalty responsibility
- consistency in penalty application
- uncertainty over trade penalties
- clarification of Customs policies and programs
- penalty level retention periods, and
- flaws of pure penalty systems

Members will recognize from this list many issues that have been on the CSCB’s agenda since prior to the implementation of AMPS. Many of these issues also have been the subject of our ongoing cooperative endeavours with the CAIE and the CME. Now we need to ensure that these issues are resolved in a manner that best serves the needs of you and your clients. Throughout the anticipated consultation period of May and June, additional information about the structure and schedule of the review will be made available. As always, your comments and your experiences with AMPS are critical to the positions that will be taken by the CSCB throughout this review. We encourage you to continue providing us with information about your AMPS experiences, and your recommendations for how the program can better meet its goal of enhanced compliance.