Misdeclaration of goods was established and the broker breached...

Misdeclaration of goods was established and the broker breached the duty to advise the client and to intimate Customs under Regulation 13(d); that failure is a serious lapse. When management became aware of the discrepancy, vicarious liability arose under Regulation 19(8) because the manager did not ensure escalation to the licence holder and onward to Customs. No violation of Regulation 13(o) was proved. Penalty should be limited to proven breaches and cancellation of the customs broker licence was not warranted.