Unauthorised lending of a Customs Broker licence and dongle to a...

Unauthorised lending of a Customs Broker licence and dongle to a G-card holder for consideration constitutes an impermissible transfer because the prohibition applies to the substance of the arrangement, not merely proprietary title. Filing a Shipping Bill in an exporter's name without that exporter's authority, while failing to verify the client's identity and functioning, independently breaches Customs Broker obligations; verification of IEC and GST particulars alone is insufficient, and knowledge of prohibited goods is unnecessary. No separate breach arose from information imparted to a client where no incorrect information was identified. Revocation, security forfeiture and penalty remained proportionate to the cumulative misconduct.