Customs Broker diligence failures justified forfeiture of security deposit, while deliberate collusion was not proved.

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....Customs Broker disciplinary liability under the CBLR, 2013 was upheld for serious failures of due diligence, supervision and verification, where the evidence showed inadequate oversight of customs clearance operations and insufficient verification of exporters' credentials. The Tribunal found these lapses sufficient to establish violations of Regulations 11(a), 11(b), 11(n) and 17(9), but it did not find conclusive proof of deliberate collusion, sharing of drawback, illegal gratification or conscious participation in the alleged fraud. On that basis, forfeiture of the security deposit was sustained as a proportionate lesser penalty, revocation of licence was not ordered, and continued suspension could not be justified merely because investigation remained pending.....