Sergei Mozer, Ph.D. at law
Senior Researcher in the Research Institute of the Russian Customs Academy.
Published: Social and political sciences. – № 4 (August). – 2019 — pages 107-115. © S.V. Mozer, 2019
When using the article referance is required
To analyze the activities of the Permanent Technical Committee (PTC) of the World Customs Organization (WCO, Organization) on the formation of the digital customs institution and form conclusions.
The research article is devoted to the issue of improvement of the instruments of customs regulation in the framework of the operation of the WCO PTC. The subject of the study is the institute of digital customs. The approaches of the Organization in 2016 are analyzed in terms of the formation of digital customs as an integrated legal phenomenon under the theme «Digital customs — progressive engagement». Conclusions are formulated on the results of the work of the WCO PTC based on relevant materials of the Organization.
The introduction of the digital customs institution into the law of the Eurasian Economic Union (EEU) and customs regulation in general is aimed at optimization of customs operations and simplification of trade.
The results of the study are of interest to the customs block of the Eurasian Economic Commission (EEC), can be used in organizing the work of the WCO Information Management Sub-Committee and the Permanent Technical Committee in the framework of the EEC — WCO international customs cooperation. The article is recommended to researchers, as well as experts from customs administrations of the EEU Member states, whose activities are related to the improvement of customs regulation, modernization of the digital customs institution, as well as international customs law.
The research material is based on an analysis of the practical aspects of WCO work and is one of the first scientific and practical publications on the development of the digital customs institution within the framework of WCO activities.
Keywords: The World Customs Organization, the WCO, the Eurasian Economic Union, EEU, the Eurasian Economic Commission, EEC, Permanent Technical Committee, e-Customs, digital Customs, customs regulation, customs administration, international customs law, customs.
Introduction. Studying the issues of improving customs regulation in the Member States of the Eurasian Union (hereinafter — the EEU, the Union), specialists of the customs block of the Eurasian Economic Commission (hereinafter — the EEC, the Commission) with professional interests are acquainted with proposals for the modernization of Union law that come from Customs Administrations, economic operators, as well as professional associations from the business community of Armenia, Belarus, Kazakhstan, Kyrgyzstan and Russia. Subsequently, as part of the rule-making process, the Commission experts, among other things, appeal to international standards, instruments and tools of customs regulation. Some of them are mandatory and are reflected in international conventions and agreements, while others are not — recommendations, guidelines, compendiums, manuals that affect various institutions of customs law, and with them customs operations, business processes.
The author’s experience of interaction with the World Customs Organization (hereinafter — the WCO, Organization) shows that the basic developments, instruments and tools of customs regulation are created in this international Organization in the context of international customs cooperation. A significant role in this work is played by the WCO Permanent Technical Committee.
For reference: the Permanent Technical Committee (hereinafter — PTC, Committee) was established on December 15, 1950 in accordance with Article V of the Convention establishing a Customs Cooperation Council. The PTC acts under the overall direction of the WCO Council and Policy Commission, with administrative support provided by the WCO Secretariat. Speaking about purpose and scope, we need to note that the functions of the PTC are to : contribute to the strategic direction of work done by
the WCO in respect of the promotion, development and administration of trade facilitation instruments and tools, in accordance with the WCO Strategic Plan; help to enhance co-operation between Customs administrations and governmental and non-governmental (private sector) organizations in the field of trade facilitation; introduce and promote initiatives aimed at improving the effectiveness of Customs through information technology and electronic commerce, Customs co-operation and the establishment of various legal instruments; develop various tools designed to enhance efficiency in trade (particularly the Guide to measure the time required for the release of goods), and promote their use by Members; contribute to the development of means and methods to facilitate, simplify and harmonize the Customs formalities applicable to postal consignments; provide strategic support for the WCO’s capacity building programmes for its Members.
In publications, whose subject of research is the Digital Customs Institute, we have already touched on the work of the Permanent Technical Committee. However, the published research materials did not address the issues of the WCO Data Model; «single window» mechanism; data security; modernization of management in customs through the use of information and communication technologies (hereinafter — ICT); Big data and data mining; risk management systems; the internet of things as well as e-commerce. WCO identifies these phenomena with the institute of digital customs. Most of these issues were submitted to experts at the 211/212 session of the PTC, which was held from March 2 to 4, 2016 at the WCO headquarters. Before forming conclusions on the results of this meeting of the Committee, we will pay attention to the efforts of the WCO to formalize the institution of digital customs in 2016.
- The Year of Digital Customs (2016). It is worth recalling, that the World Customs Organization dedicated 2016 to the theme «Digital Customs» under the slogan «Progressive Engagement». It was assumed that the WCO Members will be able to promote innovations in the field of digital customs that they have implemented. By the International Customs Day scientifically interesting explanations have been voiced with respect to the digital customs institute.
Thus, according to the WCO, the term «digital customs» refers to any automated or electronic type of activity that contributes to the effectiveness, efficiency and coordination of customs activities, such as automated customs clearance systems, the «single window» concept, electronic information exchange, websites to transmit information and ensure transparency, as well as the use of smartphones.
Information and communication technologies, as the WCO notes, are central to digital customs. They are not only ubiquitous in our workplaces, they are the main method of transmitting information to any corner of the planet. ICTs allow us to use automated customs clearance systems for receiving declarations, risk management and selectivity, conducting inspection and processing, and cargo clearance. They entail the creation of «single window» systems which are the leading innovation in trade facilitation. The roadmap for achieving digital customs is contained in Chapter 7 of the Guidelines to the General Annex to the Revised Kyoto Convention of the WCO in the section «Application of Information and Communication Technologies».
According to the WCO, the new era of digital customs has changed the way customs works. Ultimately, this provides progressive interaction — enhanced capabilities for Customs administrations to communicate, process goods, receive and share information, coordinate actions at the border, cooperate in law enforcement and promote transparency. Thus, ICTs provide many positive results for the customs service:
- Improving compliance by expanding access to regulatory information and functions, as well as services for entities engaged in international trade.
- More clearance for legitimate trading.
- Improving coordination between Customs authorities, as well as between customs and other border regulatory authorities at the national and international level.
- Increasing transparency in regulatory and decision-making processes.
- Using performance measurement to improve customs procedures and integrity, for example, using the methods presented in the WCO Performance Measurement Contracts (PMC) Guide.
- Improved detection of irregularities and illegal parties through effective data collection and analysis.
All these results lead to the achievement of customs goals, including
improved revenue collection, border security, collection of trade statistics and trade facilitation.
The WCO Communication to the International Customs Day (2016) notes that the international customs community with the motto «Digital Customs — Progressive Engagement», signals its desire to further develop the direction of digital solutions and services in order to simplify business conditions for border agencies and customs officers, as well as the intention to more broadly introduce advanced technologies, using Big data, Telematics and Cloud, to enhance operational efficiency and accelerate the modernization of business processes.
To support WCO Member countries in their efforts to further implementation of digital customs, the WCO has developed an extensive portfolio of instruments and applications. The Organization recently tested to assess these ICT-related instruments and their intended purpose. This testing goes hand in hand with the ongoing work carried out by the WCO on the ICT Guide for Executives, which was developed in the form of a concise guide which briefly discusses the key aspects of development and deployment of ICT solutions for high-ranking customs officials as well as directly for ICT project management. The WCO notes that the technological environment is changing rapidly with the emergence of a number of key areas such as Cloud computing, mobile technologies, Advanced analytics and information management. Each of these technologies has a different impact on the role of customs and provides numerous opportunities to expand links between Customs administrations, as well as with trade operators and other border
agencies, thereby increasing productivity, which leads to accelerated economic growth.
Finally, it is noted that part of the work of the WCO in the coming months will be to monitor and disseminate best practices on such diverse topics as change management, personnel policy or information management. Therefore, during 2016, the WCO Member countries were invited to promote and share information on how they adapt to the digital environment, how they use the potential of IT, as well as how they implement and use digital technologies to advance and achieve their goals, and meet the expectations participants of foreign economic activity, transport and logistics operators and governments.
- About the role of the WCO Permanent Technical Committee in the formation of the Digital Customs Institute.
In our opinion, the WCO Permanent Technical Committee plays a significant role in improving customs administration and the development of appropriate WCO instruments. After serious discussions at the 74th meeting of the Policy Commission on the fate of digital customs as well as the formation of important provisions of the analyzed institute which are set out in the WCO message to the International customs day, the PTC began to consider the practical issues of the formation of the digital customs institution.
As part of the analysis, we turn to the agenda of the 211/212 session of the Permanent Technical Committee, which took place from March 2 — 4, 2016 at the WCO Headquarters. The following issues were addressed at the meeting:
- a) Results of the discussion by the Policy Commission on digital customs.
- b) The WCO Data model as a promotion (popularization) strategy for international organizations, regional organizations and the private sector.
- c) «Single window».
- Addition of a change to the Single Window Compendium.
- Presentation of the African Union on E-Commerce.
- Measurement (evaluation) of the results related to the «single window» (presentation of the Organization for Economic Cooperation and Development).
- d) Data security.
- e) Modernization of customs management using information and communication technologies (presentations by South Africa and the USA).
- e) Handbook of the Global Customs Network (GNC).
- g) Regional approach to digital customs (Côte d’Ivoire presentation).
In order to familiarize of the PTC delegates with the WCO general line on a particular issue, its meetings traditionally summarize the results of discussions and decisions taken at the level of the Policy Commission and the WCO Council. With regard to the problems of the formation of the digital customs institute, the relevant results were announced by the WCO Secretariat represented by the Director of the Compliance and Facilitation Directorate. In particular, feedback was provided on the results of discussions on digital customs at the 74th session of the Policy Commission, held in December 2015 in Punta Cana. The Directorate General noted that the WCO Secretary General presented this initiative, stating that the concept of digital customs is intended to provide a holistic understanding of the WCO instruments and guidelines related to information and communication technology standards and how they are related to the cross-border and operational area.
Digital customs includes functions for simplification of procedures, law enforcement, revenues, and also covers both strategic and operational aspects. In the opinion of the WCO Secretariat, this topic should have been considered at upcoming regional meetings.
Among other things, the opinion of the delegates of the Policy Commission was voiced that the concept of digital customs should be understood as a means and not as a goal, and the focus should be not just the automation of existing bureaucratic processes. In addition to this, the Director of the Directorate drew attention to the position voiced at the 74th session of the Policy Commission on the need to involve all interested parties involved in cross-border trade in the process of forming the institution of digital customs. In our opinion, this proposal should also be used for the Eurasian Economic Union.
Whenever we substantively study the WCO’s working materials under the general sign of «Digital Customs — Progressive Engagement», we try to find this digital customs in analytical materials, references, reports, positions of the parties. It is important for us to understand the logic of documents, the system of positions of the WCO Member states and experts of the Secretariat as well as the decisions that are directly related to this institution. And in the dynamics. This time in March 2016 at the session of the Permanent Technical Committee under the above-mentioned slogan experts from the Customs administrations of the WCO Member states considered such complex institutions as Big data, Data mining, and the WCO Data Model. Among other things, they considered such phenomena, instruments, tools, processes as the Internet of things, Risk Management System, digital solutions and services, digital tools, analytical tools, data processing technologies, international standards, distribution of limited labor resources, the AEO institute and the security chain of goods, prevention of violations of customs legislation, modeling business processes.
Let us pay attention to the emergence in the formed conceptual apparatus of such terms as digital cooperation, digital trust, digital coordination, new classes of economic operators, electronic trading platforms, financial intermediaries, financial payment gateways as well as transporters and carriers. No less important are the positioning of the problem of creating an effective mechanism for interaction of experts of the WCO working bodies with international organizations and the business community.
It is obvious to us that the future customs or, in a different way, e-customs becomes intellectual and should be implemented in a single system of coordinates with ascribed phenomena (elements. instruments).
Let’s consider the PTC materials proposed to the international customs community at the 211/212 meeting of the Permanent Technical Committee in the period from 2 to 4 March 2016. Due to the limitations of the volume of the research article, we reflect the main conclusions, which are based on a comprehensive analysis of the working materials of the PTC.
A comprehensive analysis of the PTC materials on the creation of digital customs made it possible to formulate the following conclusions:
- The Permanent Technical Committee is an important WCO working body, which is directly involved in the formation of modern customs regulation instruments, including the creation of a digital customs institution. In modern conditions of customs development, the topic of creating such a customs remains relevant for the Council, the Policy Commission, the Information Management Sub-Committee, the Law Enforcement Committee, and the WCO Capacity Building Committee.
- 2.5 months after the 209/2010 session of the PTC and the Policy Commission, the World Customs Organization formally formulated a number of important provisions on the institution of digital customs. These provisions were announced by the International Customs Day, which is traditionally celebrated by the international customs community on January 26.
- Without specifying specifically what is digital customs, the WCO stated the position that the term «digital customs» refers to any automated or electronic activity that contributes to the effectiveness, efficiency and coordination of customs activities, such as automated customs clearance systems, the «single window» concept, electronic information exchange, websites for transmitting information and ensuring transparency, and the use of smartphones.
Let us ask ourselves whether an automated workplace of economic operator and its corresponding activity (electronic — from the WCO definition) when interacting with Customs authorities, for example, when submitting a declaration or additional information about a product, is digital customs? Is the use of a smartphone by an economic operator within its local automated system is a digital customs? Based on the proposed definition of the WCO, the answer is likely to be positive. However, is this true? Here we are talking about «any electronic activity», but we call customs «digital» (!). And can we talk about e-customs in case of contact with any electronic or automated activity that contributes to the effectiveness, efficiency and coordination of customs activities? Let’s pay attention to another aspect. Accepting the above-mentioned definition of digital customs, we must agree with the thesis that the «single window» mechanism is, in fact, an electronic customs. But is it so? In our opinion, first we need to determine the Reference model of digital customs, determine its scope, range of subjects, categories of legal relations and their subject matter. It is important to understand the relationship between digital customs and ICT, the «single window» mechanism, information systems, software, electronic (digital) activities, etc. It is clear that in order to adopt such a concept of digital customs, we need appropriate scientific and practical explanations. Otherwise, it raises more questions than answers.
- According to the WCO information and communication technologies, being the main method of transmitting information, occupy a central place in digital customs. Let’s pay particular attention to the fact that for this case digital customs is not identified with ICT. And this, in our opinion, deserves attention. ICTs really occupy an important place, but they are not digital customs in their pure form. Otherwise, based on the above-mentioned definition of the term «digital customs», it can be erroneously argued that the «single window» mechanism is pure ICT. Despite this, the WCO Strategic Plan is in fact equated with digital customs and ICT.
- It’s not easy for us to agree with the thesis that the Roadmap for achieving digital customs is contained in Chapter 7 of the Guidelines to the General Annex to the Revised Kyoto Convention of the WCO in the section «Application of Information and Communication Technologies». The fact is that this Guide does not use the term «digital customs» at all. Accordingly, additional explanations are needed as to how the Guide can be a plan of action, especially when there is no Concept or Reference model of digital customs. On the other hand, for researchers who identify digital customs with ICT, the above-mentioned thesis on an action plan can be quite acceptable and undeniable.
- Analysis of the WCO Communication for the International Customs Day (2016) allows to highlight characteristics (phenomena, mechanisms, advanced technologies, key areas, etc.), as well as the conceptual apparatus that complement the comprehensive picture of the digital customs institution being developed. Among them are the following (Picture 1):
- Automated activity.
- Electronic activity.
- Electronic solutions.
- Automated customs clearance systems.
- «Single window» mechanism.
- Digital environment.
- Digital technologies.
- Information and communication technologies.
- Use of the smartphone.
- Big data.
- Cloud computing.
- Mobile technologies.
- Advanced analysis tools and information management.
In our opinion, the listed elements are subject to further more detailed analysis in the context of the formation of the institute (agenda) of digital customs.
Picture 1. Characteristics of digital customs under the WCO theme «Digital Customs — Progressive Engagement»
- In March 2016 the international customs community has already considered digital customs in the context of such phenomena, technologies, characteristics, as automated activities; electronic activity; electronic solutions; automated customs clearance systems; «single window» mechanism; digital environment; digital technology; information and communication technologies; advanced analysis tools and information management; data processing technology; mobile technology; using a smartphone; Internet of things; Big data; telematics; Cloud resources; «Cloud» computing; digital solutions and services; digital tools; analytical tools; international standards; AEO institute and security supply chain; prevention of violations of customs legislation; business process modeling; risk management system; distribution of limited labor resources.
- The creation of digital customs involves the optimization (reengineering) of business processes (customs operations) and the use of technology as an instrument for the transition from manual processing to digital processes.
In the context of digitalization, the following components are subject to investigation: a policy (search for improvements in the implemented policy to simplify procedures, process, operations); human resources (to develop a culture that can innovate, educate and constantly improve); procedures, operations (to compose, understand and optimize processes, operations); technology (convert from manual to digital).
- The concept of digital customs has not yet been formed, but the thesis of the need to create it continues to be relevant.
According to the WCO, the digital customs concept is designed to provide a holistic understanding of the WCO instruments and guidelines related to information and communication technology standards and how they are related to the cross-border and operational area.
Digital Customs, as understood by the WCO Secretariat, includes functions for simplification of procedures, law enforcement, revenues, and also covers both strategic and operational aspects. While the concept of digital customs should be understood as a means, not as a goal, and the focus should be not just the automation of existing bureaucratic processes.
The concept encourages customs to introduce ICT solutions to more effectively and efficiently achieve goals. It also suggests that technology deployment should not only focus on the customs environment, but also include coordination with other partner regulatory agencies regulating border crossing issues.
At the meetings of the Policy Commission the concept of digital customs was not limited to the exchange of information through standards, protocols and guidelines for achieving interaction between stakeholders in different countries, between customs as well as with trade. Accordingly, convergence of digital customs only to the exchange of information between customs and stakeholders, does not fully interpret the existing approaches to development of the digital customs institution. Digital customs includes a wider range of issues, and it should not be limited only to information exchange issues.
- For the development of the digital customs institution, it is necessary to involve international organizations, regional entities and the private sector in the process of improving customs administration instruments.
In accordance with international practice, all interested parties from the private sector are involved in the process of modernization and transition to digital customs from the concept development stages to the testing phase, before proceeding to implementation.
- The concept of digital customs is considered in the WCO in the context of the implementation of the «single window» mechanism. However, it is not digital customs that is being discussed as a complex phenomenon, but a «single window» mechanism. It is noted that «single window» tools (Compendium, Supplement) contribute to the goals of the digital customs concept. At the same time, the main question of what digital customs is and how the institution of digital customs correlates with the «single window» remains outside the scope of discussions.
The PTC decisions concern not the institution of digital customs, but the «single window» mechanism.
Discussions on digital customs should be focused not only on the important results of the work of the WCO working bodies, associated with the implementation of the «single window» mechanism, but also on digital customs directly. According to the author, the project «single window» should be considered in relation to the institute of digital customs. It is important to distinguish the characteristics of digital customs from the characteristics of the «single window» mechanism. Such an analysis does not exist at present moment.
- The development of the digital customs institute is linked to data security, cybersecurity and confidentiality in establishing digital cooperation within a «single window» or in the context of regional integration.
- Information security requirements are an important part of digital coordination in order to guarantee a level of trust for each public authority with cooperation is performed.
The WCO provides only a review of the standards and recommends that Member countries refer to the relevant ISO 27000 family to guide them in organizing information security management.
Among other things, the goal of information security management is to increase digital confidence in digital collaboration and the exchange of information by all stakeholders.
- The Revised Kyoto Convention does not contain the term «digital customs» or «electronic customs». There is no corresponding definition in the WCO Guidelines on Information Customs Technologies to the Kyoto Convention.
The translation of standard 7.2. of the General Annex of the Kyoto Convention into Russian, which is posted on the WCO official website, is incorrect. In particular, the standard (in English) deals with the introduction of «computer applications (programs)» and not «computer systems». This fact is misleading the Russian-speaking segment of researchers and users of the Revised Kyoto Convention in this part.
The WCO experts’ interpretation of the standard 7.2 of the Convention on the implementation of «information technologies» does not comply with the text of the standard, since it is a question of introducing «computer applications».
The Kyoto Convention does not disclose the term «computer applications (programs)». There is no answer to this question in the WCO Guide on Information Customs Technologies to the Kyoto Convention.
Standard 7.4 of the General Annex of the RKC does not contain any data protection provisions. This standard deals with customs legislation in terms of the methods used for the exchange of commercial information, methods of authentication and identity of documents as well as the right of the customs service to keep information for customs purposes. The same standard, along with electronic means (methods) of exchanging commercial information, permits the provision of documents on paper; application of authentication methods and identity documents on paper.
In our opinion, digital customs as well as the «single window» mechanism, are phenomena of a new evolutionary, technological level, stage of development of modern customs, which follows electronic customs.
— 112 —
Accordingly, the formation of an institution of digital customs on standards combining paper-based information methods and at the same time electronics methods does not fully fit into the concept of digital customs.
The WCO needs to create a Reference model of digital customs in which the use of paper (method) is minimized.
The Kyoto Convention has not been reviewed for 20 years. Taking into account the digital revolution that has taken place and the modern level of development of ICT, the assertion that this WCO instrument forms the institute of digital customs does not correspond to objective reality.
- Within the framework of the digital customs concept, the WCO intended to provide a single reference point to Member states for a holistic understanding of all the instruments, standards and guidelines of the WCO related to ICT, and how they relate to the area of cross-border regulation and are inherent in this area.
- The Global Customs Network plays an important role in the development of the digital customs institution. It allowed the development of international standards that contribute to the implementation of efforts to introduce digital customs.
- At the regional level, the development of the digital customs institute involves the creation of an effective project management mechanism. It is preceded by the preparation of a regional development plan for the digital customs institute, and with it information communication technologies.
In addition to this, it is necessary to develop an action plan that identifies specific steps and actions carried out by the interested Member countries of the regional entities.
Among the regional problems of digital customs formation are the following: status and integration into the work of ICT experts in customs, obsolete websites, lack of documented ICT procedures, ICT security policy, planning for continuity and concepts of disaster recovery and poor implementation of international standards and best practices (for example, ISO 2700).
The study of regional experience in creating an institution of digital customs is of interest to the Eurasian Economic Union, which includes Armenia, Belarus, Kazakhstan, Kyrgyzstan and Russia.
- Big data, Data mining as well as the Data Model are digital instruments and are considered by international experts as elements of digital customs. These tools allow to assess trends, patterns, gaps and potential indicators of cross-border trade and e-customs activities.
In this key, the creation of digital customs requires the development of certain analytical tools, technologies for Big data processing, Data mining as well as the implementation of its functions by customs, taking into account the development of the Internet of things technology.
Big data alone will not change customs operations, but the inclusion of Big data in the work of the customs authorities will contribute to this.
The use of Big data in customs activities can contribute to the optimal allocation of organizational resources.
Customs authorities should move from electronic processing of customs declarations and physical control of goods to using the Big data environment using Data mining and predictive analytics.
- To implement the necessary digital technical and technological innovations, modernization of customs legislation is required.
- The development of the digital customs institution is based on the functioning of the RMS institute as well as its modernization, taking into account the potential possibility of including Big data in the risk management process. An actual issue is digitization in the area of customs risk management.
- Digital customs is related to the AEO Institute and the issues of a security supply chain; helps to prevent violation of customs regulations. An actual issue is the improvement of access to commercial information directly or indirectly related to trade operations implemented by a new class of economic entities (economic operators).
- In our opinion, at the conceptual level (in the future the Concept of e-customs), the scope of e-customs should be defined, to which we include (1) the scope of regulation, (2) activities and (3) subjects. As part of the PTC meeting in March 2016, the WCO experts among other things affected the activities of such entities as customs, electronic commerce intermediaries (electronic trading platforms, financial intermediaries, financial payment gateways as well as transporters and carriers).
- The WCO Data model provides a global standard for international data requirements for the release and clearance of goods.
The WCO Data model is the «language of customs» for the development of interconnectedness and modernization of ICT.
Since customs cannot develop business process models for non-customs processes in the field of regulating transactions involving the cross-border movement of goods, the participation of international partner organizations is important in the activities of the WCO working bodies. The World Customs Organization also names the Eurasian Economic Commission among the partners that may be involved in such work. In turn, the EEС experts are ready to participate in this process.
- The National Customs Enforcement Network (nCEN) plays an important role in shaping the institution of digital customs, including the digitization of daily customs operations and the optimization of law enforcement and cooperation processes. This system helps to digitize customs operations, supporting efficient resource management, allowing middle executives to have an idea of their employees’ activities and task distribution, thus offering a broader picture of the efficiency of workflow processes in the field (on place).
- During the discussions on future customs, different opinions were
expressed, among which — customs deals only with tangible (physical) goods and, therefore, digital transmissions should not have implications for customs operations, although it is important to continue to closely monitor developments in the future. What does this thesis mean? Customs is for us not some abstracts and a virtual concept, but a real organization with its structure and management mechanisms, work programs, work plans, positions of customs officials and, of course, information technologies and information systems. Without having a fundamental Concept of digital customs, its development programs (for example, as an AEO program) at the WCO level, without scientifically-methodical recommendations on the establishment of an institution of digital customs in the WCO Member states, it is not easy for us to agree with the thesis about identifying customs only with information and communication technologies.
LIST OF SOURCED USED
- Kadyrkulov M.A., Mozer Sergei, Lipatova N.G. The World Customs Organization asa Modern Institute of Improvement of Customs Regulation and Trade Facilitation: a monograph. Lyubertsy: Publishing house of the Russian Customs Academy, 2017.URL: http://customs-academy.net/wp-content/uploads/2018/11/Мон.–ВТамО_Кадыркулов_Мозер_Липатоваpdf (date of the request: 27.06.2019).
- Mozer Sergei. Actual issues of the development of the e-customs institute within the framework of the WCO Information Management Sub-Committee // Gaps in Russian legislation. – №3. – 2019. URL: http://customs-academy.net/?p=12401 (date of the request: 27.06.2019).
- Mozer Sergei. Classification of topical issues of the digital customs institution at the World Customs Organization // Social and political sciences. — № 3 (June). — 2019. URL: http://customs-academy.net/?p=12638 (date of the request: 27.06.2019).
- Mozer Sergei. Improvement of customs regulation: on the strategic concept of digital customs of the World Customs Organization // Gaps in Russian legislation. — № 4 (July). — 2019. URL: http://customs-academy.net/?p=3817 (date of the request: 27.06.2019).
- Mozer Sergei. Digital Customs. WCO Experience: monograph /S.V. Mozer. Moscow: Publishing House of the Russian Customs Academy, 2019. URL: http://customs-academy.net/?p=12502 (date of the request: 28.06.2019).
- Convention establishing a Customs Co-operation Council. Signed on December 15, 1950, entered into force on November 4, 1952. URL: http://www.wcoomd.org/-/media/wco/public/global/pdf/about-us/legal-instruments/conventions-and-agreements/ccc/convccc.pdf?la=en (date of the request: 01.03.2019).
- International Convention on the Simplification and Harmonization of Customs Procedures. URL: http://www.wcoomd.org/en/topics/facilitation/instrument-and-tools/conventions/pf_revised_kyoto_conv/kyoto_new/preamble.aspx#ar8 (date of the request: 01.03.2019).
- Application of information and communication technology. Chapter 7. General Annex Guidelines. Kyoto Convention. URL: http://www.wcoomd.org/-/media/wco/public/global/pdf/topics/facilitation/instruments-and-tools/tools/ict-guidelines/ict-guidelines.pdf?db=web (date of the request: 01.03.2019);
- General information: ICT Guidelines. World Customs Organization. URL: http://www.wcoomd.org/en/Topics/Facilitation/Instrument%20and%20Tools/Tools/ICT%20Guidelines (date of the request: 01.03.2019).
- WCO Strategic Plan 2016/2017 to 2018/2019. World customs Organization. URL: http://www.wcoomd.org/~/media/WCO/Public/Global/PDF/About%20us/Administrative%20Documents/Strategic%20Plan%20part%20I%20Members%20and%20Public.ashx (date of the request: 06.03.2019).
- Summary Report. 211th/212th Sessions of the Permanent Technical Committee, 2-3 March 2016. Doc. Brussels, 11 March 2016.
- Terms of Reference for the Permanent Technical Committee. URL: http://www.wcoomd.org/en/about-us/wco-working-bodies/procedures_and_facilitation/permenant_technical_committee.aspx (date of the request: 06.03.2019).
- Letter of the Secretary General Mr. Kunio Mikuriya. № 15.SLO314E. Brussels, 12 November 2015.
- Message from the World Customs Organization. International Customs Day 2016. URL: http://www.wcoomd.org/-/media/wco/public/global/pdf/about-us/international-customs-day/2016/wco_sg-message-icd-2016-ru.pdf?db=web (date of the request: 09.03.2019).
- A Focus on Digital Customs. Draft Agenda and Programme of Work of the Permanent Technical Committee. Permanent Technical Committee. 211th /212th Sessions, 2 – 4 March 2016. Doc. PC0433E1c, Brussels, 17 February 2016.
- Compliance and Facilitation. World Customs Organization. URL: http://www.wcoomd.org/en/about-us/wco-secretariat/the-directorates/compliance-and-facilitation.aspx (date of the request: 25.03.2019).
 Terms of Reference for the Permanent Technical Committee. URL: http://www.wcoomd.org/en/about-us/wco-working-bodies/procedures_and_facilitation/permenant_technical_committee.aspx (date of the request: 06.03.2019).
 Kadyrkulov M.A., Mozer Sergei, Lipatova N.G. The World Customs Organization as a Modern Institute of Improvement of Customs Regulation and Trade Facilitation: a monograph. Lyubertsy: Publishing house of the Russian Customs Academy, 2017. – p. 75-77. Read.
 Letter of the Secretary General Mr. Kunio Mikuriya. № 15.SLO314E. Brussels, 12 November 2015.
 Application of information and communication technology. Chapter 7. General Annex Guidelines. Kyoto Convention. URL: http://www.wcoomd.org/-/media/wco/public/global/pdf/topics/facilitation/instruments-and-tools/tools/ict-guidelines/ict-guidelines.pdf?db=web (date of the request: 01.03.2019); General information: ICT Guidelines. World Customs Organization. URL: http://www.wcoomd.org/en/Topics/Facilitation/Instrument%20and%20Tools/Tools/ICT%20Guidelines (date of the request: 01.03.2019).
 Communication from the World Customs Organization. International Customs Day 2016. URL: http://www.wcoomd.org/-/media/wco/public/global/pdf/about-us/international-customs-day/2016/wco_sg-message-icd-2016-ru.pdf?db=web (date of the request: 09.03.2019).
 A Focus on Digital Customs. Draft Agenda and Programme of Work of the Permanent Technical Committee. Permanent Technical Committee. 211th /212th Sessions, 2 – 4 March 2016. Doc. PC0433E1c, Brussels, 17 February 2016.
 See Compliance and Facilitation. World Customs Organization. URL: http://www.wcoomd.org/en/about-us/wco-secretariat/the-directorates/compliance-and-facilitation.aspx (date of the request: 25.03.2019).
 Item 12. Summary Report. 211th/212th Sessions of the Permanent Technical Committee, 2-3 March 2016. Doc. PC0449E1a. Brussels, 11 March 2016. – P. 3.
 See WCO Strategic Plan 2016/2017 to 2018/2019. World customs Organization. – P. 6. URL: http://www.wcoomd.org/~/media/WCO/Public/Global/PDF/About%20us/Administrative%20Documents/Strategic%20Plan%20part%20I%20Members%20and%20Public.ashx (date of the request: 06.03.2019).
 Application of information and communication technology. Chapter 7. General Annex Guidelines. Kyoto Convention. URL: http://www.wcoomd.org/-/media/wco/public/global/pdf/topics/facilitation/instruments-and-tools/tools/ict-guidelines/ict-guidelines.pdf?db=web (date of the request: 01.03.2019).