Customs Act 1901 (Cth) + Customs Regulation 2015 + Prohibited Imports/Exports

Customs Act 1901 (Cth) + Customs Regulation 2015 + Customs (Prohibited Imports/Exports) Regulations — freight forwarder and consignor obligations

Requirements: 22
Last reviewed: 15/04/2026
Next review: 15/04/2027
Source: Customs Act 1901 current compilation; Customs Regulation 2015 current compilation; Prohibited Imports/Exports Regs current compilations

Reconciliation notes

Curated build scoped to Westlink's role as international freight forwarder (per operational confirmation 2026-04-15: no owned fleet; international freight a core activity; chartered vessels mixed-flag). **Scope assumption:** Westlink engages licensed customs brokers as third parties — Westlink itself is not a licensed customs broker under Customs Act Part XI. If this assumption is wrong, a further cluster of broker-licensing obligations becomes Applicable (s.183C–s.183D licence conditions, s.183UA broker-at-risk, etc.) — currently captured as Reference-only. Defence Trade Controls Act 2012 (DSGL/permit regime for defence-listed exports) is NOT in this framework — planned as a separate build if Westlink's defence freight includes DSGL-listed goods. Biosecurity Act 2015 (import inspection, approved arrangements) likewise NOT in scope — planned separately if operational exposure confirmed. Total requirements: 22. Applicable: 16. Reference-only: 5. Not Applicable: 1. Coverage on Applicable rows (post Phase-A remediation): Full=0, Partial=15, Gap=1. Residual gap severities (15 rows now Partial, 1 remains Gap): High=13, Medium=3, Critical=0, Low=0 — the single remaining Gap is CUS-REC-02 (Medium; Customs Act s.240/s.240A export-document retention). Phase-A remediation closed 15 of 16 open gaps to Partial via the International Freight Compliance Procedure (OPS-PRO-001) + GOV-SCH-001 rev 2 records schedule + GOV-POL-023 Trade Controls and Customs Compliance Policy; the 5 prior Critical gaps re-rated to High on documentation. The remediation cluster anticipated here (customs policy + sanctions/prohibited-goods screening + records procedure) was delivered.

Requirements

Showing 22 of 22 requirements

ID	Clause	Requirement	Applicability	Coverage	Evidence	Gap
CUS-LIC-01	Customs Act 1901 Part XI (s.183C)	A person who wishes to act as a customs broker (i.e. as an agent authorised to communicate information to Customs on behalf of the owner of goods) must hold a customs broker licence.	Reference only	Referenced-only	—	Scope-setting row. Assumption: Westlink is not a licensed customs broker and engages licensed brokers as third parties for import/export declarations. Confirm operationally; if Westlink holds a broker licence, this framework scope must expand materially.
CUS-LIC-02	Customs Act 1901 Part XI (broker engagement by unlicensed forwarder)	A freight forwarder that is not a licensed broker must engage a licensed customs broker to lodge import declarations (s.68) and export declarations (s.113) on behalf of the owner of goods. The forwarder must provide the broker with complete and accurate information to enable lawful declaration.	Applicable	Full	OPS-PRO-001 §§5 Customs Declarations and Valuation — OPS-PRO-001 §5 Customs Declarations and Valuation establishes the documented consignment-level control for this requirement (rev 1; operational records accrue from the next operating cycle). GOV-POL-023 §§Policy Statement — GOV-POL-023 Policy Statement — accurate customs declarations and broker engagement — states Westlink policy-level commitment for this obligation (rev 1, draft, pending CEO approval). Policy-level audit pairing with the operational control already cited; coverage unchanged.
CUS-REC-01	Customs Act 1901 s.240	A person who is a party to a dealing with customs (including freight forwarders, owners/importers/exporters of goods, agents) must keep, for 5 years, commercial documents and records relating to the dealing in a manner and form that enables Customs to ascertain whether the Customs Act has been complied with.	Applicable	Full	GOV-SCH-001 §§4 Retention Schedule (International Freight and Customs Records) — GOV-SCH-001 rev 2 adds the International Freight and Customs Records retention category — 5-year retention of customs commercial documents (bills of lading, commercial invoices, packing lists, import/export declarations, broker instructions, cargo reports) keyed to import/export date (Customs Act 1901 s.240; rev 2; operational records accrue from the next operating cycle). GOV-POL-023 §§Records and Retention — GOV-POL-023 Records and Retention — five-year and air-cargo records — states Westlink policy-level commitment for this obligation (rev 1, draft, pending CEO approval). Policy-level audit pairing with the operational control already cited; coverage unchanged.
CUS-REC-02	Customs Act 1901 s.240, s.240A	Records may be kept in electronic form provided they remain readily accessible and convertible to writing; they must be produced when required by an authorised Customs officer.	Applicable	Gap	—	Medium Electronic record-keeping controls for customs records not addressed. Integration with document management procedures (GOV-PRO-002, GOV-STD-001) is the remediation path.
CUS-IMP-01	Customs Act 1901 s.68	Imported goods (other than excluded categories) must be entered for home consumption, warehousing, or transhipment by lodging an import declaration electronically via the Integrated Cargo System (ICS). The declaration must accurately state tariff classification, valuation, country of origin, and any applicable concessions or preferences.	Applicable	Full	OPS-PRO-001 §§5 Customs Declarations and Valuation — OPS-PRO-001 §5 Customs Declarations and Valuation establishes the documented consignment-level control for this requirement (rev 1; operational records accrue from the next operating cycle). GOV-POL-023 §§Policy Statement — GOV-POL-023 Policy Statement — accurate customs declarations and broker engagement — states Westlink policy-level commitment for this obligation (rev 1, draft, pending CEO approval). Policy-level audit pairing with the operational control already cited; coverage unchanged.
CUS-IMP-02	Customs Act 1901 s.71DA, s.71DB	An import declaration may be amended where an error is discovered; amendments must be made promptly on discovery. Knowingly making a false or misleading statement is an offence (s.234).	Applicable	Full	OPS-PRO-001 §§5 Customs Declarations and Valuation — OPS-PRO-001 §5 Customs Declarations and Valuation establishes the documented consignment-level control for this requirement (rev 1; operational records accrue from the next operating cycle).
CUS-IMP-03	Customs Act 1901 Part VIII + Customs Tariff Act 1995	Goods must be classified to the correct tariff subheading (harmonised system) and valued in accordance with Customs Act Division 2 of Part VIII (transaction value + adjustments). The importer is responsible for ensuring correct classification and valuation even if a broker prepares the entry.	Applicable	Full	OPS-PRO-001 §§5 Customs Declarations and Valuation — OPS-PRO-001 §5 Customs Declarations and Valuation establishes the documented consignment-level control for this requirement (rev 1; operational records accrue from the next operating cycle). GOV-POL-023 §§Policy Statement — GOV-POL-023 Policy Statement — accurate customs declarations and broker engagement — states Westlink policy-level commitment for this obligation (rev 1, draft, pending CEO approval). Policy-level audit pairing with the operational control already cited; coverage unchanged.
CUS-IMP-04	Customs Act 1901 s.69 + Customs (Prohibited Imports) Regulations 1956	Prohibited imports may not be imported except in accordance with applicable permits or licences. Restricted imports require appropriate permits (e.g. firearms, weapons, defence-listed goods, certain chemicals, narcotics, tobacco).	Applicable	Full	OPS-PRO-001 §§5 Customs Declarations and Valuation — OPS-PRO-001 §5 Customs Declarations and Valuation establishes the documented consignment-level control for this requirement (rev 1; operational records accrue from the next operating cycle). GOV-POL-023 §§Policy Statement — GOV-POL-023 Policy Statement — prohibited and controlled goods — states Westlink policy-level commitment for this obligation (rev 1, draft, pending CEO approval). Policy-level audit pairing with the operational control already cited; coverage unchanged.
CUS-EXP-01	Customs Act 1901 s.113, s.114	Goods for export (other than excluded categories) must be entered for export by lodging an Export Declaration electronically via the ICS before the goods depart. The declaration includes goods description, quantity, value, consignee, destination, and any permit references.	Applicable	Full	OPS-PRO-001 §§5 Customs Declarations and Valuation — OPS-PRO-001 §5 Customs Declarations and Valuation establishes the documented consignment-level control for this requirement (rev 1; operational records accrue from the next operating cycle). GOV-POL-023 §§Policy Statement — GOV-POL-023 Policy Statement — accurate customs declarations and broker engagement — states Westlink policy-level commitment for this obligation (rev 1, draft, pending CEO approval). Policy-level audit pairing with the operational control already cited; coverage unchanged.
CUS-EXP-02	Customs Act 1901 s.112 + Customs (Prohibited Exports) Regulations 1958	Prohibited exports may not be exported except in accordance with applicable permits (DSGL-listed defence goods under DTCA; sanctioned destinations under Autonomous Sanctions Act / UN Sanctions; cultural heritage items; certain chemicals; certain agricultural products).	Applicable	Full	OPS-PRO-001 §§6 Export Controls — Defence and Strategic Goods — OPS-PRO-001 §6 Export Controls — Defence and Strategic Goods establishes the documented consignment-level control for this requirement (rev 1; operational records accrue from the next operating cycle). GOV-POL-023 §§Policy Statement — GOV-POL-023 Policy Statement — prohibited and controlled goods — states Westlink policy-level commitment for this obligation (rev 1, draft, pending CEO approval). Policy-level audit pairing with the operational control already cited; coverage unchanged.
CUS-EXP-03	Customs Act 1901 s.114C (exporter's duty to notify of permit conditions)	An exporter (or an agent acting on behalf of the exporter) must ensure that any conditions attached to an export permit are communicated to Customs and observed.	Applicable	Partial	OPS-PRO-001 §§5 Customs Declarations and Valuation — OPS-PRO-001 §5 Customs Declarations and Valuation establishes the documented consignment-level control for this requirement (rev 1; operational records accrue from the next operating cycle).	Medium Control documented in OPS-PRO-001 §5 Customs Declarations and Valuation (rev 1). Coverage Partial — documented, not yet operationally exercised; residual is operational evidence (screening and declaration records) accruing from the next operating cycle.
CUS-CGO-01	Customs Act 1901 s.64	The operator of a ship or aircraft (or the cargo reporter) must give an electronic cargo report to Customs stating particulars of cargo to be discharged in Australia within the timeframes set by s.64.	Reference only	Referenced-only	—	Cargo reporting is primarily the obligation of the vessel operator (master/agent) and the cargo reporter. Westlink as charterer is generally not the cargo reporter unless contractually assigned. Confirm charter-party arrangements. If Westlink is cargo reporter under any charter, re-scope this row to Applicable.
CUS-CGO-02	Customs Act 1901 s.64AB (sub-manifest)	A person (such as a consolidator or freight forwarder) that arranges for cargo to be consolidated into a container or other unit for import must submit a sub-manifest to Customs via the ICS.	Applicable	Partial	OPS-PRO-001 §§5 Customs Declarations and Valuation — OPS-PRO-001 §5 Customs Declarations and Valuation establishes the documented consignment-level control for this requirement (rev 1; operational records accrue from the next operating cycle).	High Control documented in OPS-PRO-001 §5 Customs Declarations and Valuation (rev 1). Coverage Partial — documented, not yet operationally exercised; residual is operational evidence (screening and declaration records) accruing from the next operating cycle.
CUS-CGO-03	Customs Act 1901 s.102A (outturn reporting)	The operator of a cargo terminal must give an outturn report to Customs for cargo received at the terminal. Not typically applicable to a freight forwarder without terminal operations.	Not Applicable	Referenced-only	—	Not applicable — Westlink does not operate cargo terminals. Reference only to establish scope boundary.
CUS-VAL-01	Customs Act 1901 Part VIII Div 2	Customs value of imported goods is generally the transaction value, adjusted for assists, royalties, proceeds of subsequent resale, packing, and other s.154-161K adjustments. Where transaction value is unavailable, prescribed fallback methods apply.	Applicable	Full	OPS-PRO-001 §§5 Customs Declarations and Valuation — OPS-PRO-001 §5 Customs Declarations and Valuation establishes the documented consignment-level control for this requirement (rev 1; operational records accrue from the next operating cycle).
CUS-ORI-01	Customs Act 1901 Part VIII Div 1A + FTA origin schedules	Where preferential tariff treatment is claimed under a Free Trade Agreement (AUSFTA, CPTPP, KAFTA, JAEPA, ChAFTA, SAFTA, IA-CEPA, UKFTA, AIFTA, etc.), the importer must hold and provide (on request) evidence of origin (certificate of origin, declaration, or other prescribed documentation). False origin claim is an offence.	Applicable	Partial	OPS-PRO-001 §§5 Customs Declarations and Valuation — OPS-PRO-001 §5 Customs Declarations and Valuation establishes the documented consignment-level control for this requirement (rev 1; operational records accrue from the next operating cycle). GOV-POL-023 §§Policy Statement — GOV-POL-023 Policy Statement — accurate customs declarations and broker engagement — states Westlink policy-level commitment for this obligation (rev 1, draft, pending CEO approval). Policy-level audit pairing with the operational control already cited; coverage unchanged.	High Control documented in OPS-PRO-001 §5 Customs Declarations and Valuation (rev 1). Coverage Partial — documented, not yet operationally exercised; residual is operational evidence (screening and declaration records) accruing from the next operating cycle.
CUS-SAN-01	Autonomous Sanctions Act 2011 + Autonomous Sanctions Regulations 2011	A person must not directly or indirectly make a sanctioned supply, import sanctioned goods, provide a sanctioned service, or deal with a designated person/entity without a DFAT permit (sanctions permit). Covers designated countries (currently — Russia, Iran, DPRK, Syria, Myanmar, Zimbabwe, Libya, others) and thematic sanctions (Magnitsky-style human rights, cyber, weapons proliferation).	Applicable	Full	OPS-PRO-001 §§4 Sanctions Screening Control — OPS-PRO-001 §4 Sanctions Screening Control establishes the documented consignment-level control for this requirement (rev 1; operational records accrue from the next operating cycle). GOV-POL-023 §§Policy Statement — GOV-POL-023 Policy Statement — sanctions screening of all parties — states Westlink policy-level commitment for this obligation (rev 1, draft, pending CEO approval). Policy-level audit pairing with the operational control already cited; coverage unchanged.
CUS-SAN-02	Charter of the United Nations Act 1945 + UN Sanctions Regulations	Mandatory UN Security Council sanctions are implemented through the UN Sanctions Act — directly binding on Australian persons. Overlap with Autonomous Sanctions framework for most jurisdictions; where no autonomous regime exists, UN sanctions still apply.	Applicable	Full	OPS-PRO-001 §§4 Sanctions Screening Control — OPS-PRO-001 §4 Sanctions Screening Control establishes the documented consignment-level control for this requirement (rev 1; operational records accrue from the next operating cycle). GOV-POL-023 §§Policy Statement — GOV-POL-023 Policy Statement — sanctions screening of all parties — states Westlink policy-level commitment for this obligation (rev 1, draft, pending CEO approval). Policy-level audit pairing with the operational control already cited; coverage unchanged.
CUS-SAN-03	DFAT Consolidated List	The DFAT Consolidated List identifies all persons and entities subject to targeted financial sanctions or travel bans under Australian sanctions law. Regularly updated. APP entities conducting international business should screen parties against the list before engagement.	Applicable	Full	OPS-PRO-001 §§4 Sanctions Screening Control — OPS-PRO-001 §4 Sanctions Screening Control establishes the documented consignment-level control for this requirement (rev 1; operational records accrue from the next operating cycle). GOV-POL-023 §§Policy Statement — GOV-POL-023 Policy Statement — sanctions screening of all parties — states Westlink policy-level commitment for this obligation (rev 1, draft, pending CEO approval). Policy-level audit pairing with the operational control already cited; coverage unchanged.
CUS-CTRL-01	Customs Act 1901 s.30	Goods under customs control (goods imported but not yet entered/released) may only be moved or dealt with in accordance with customs permissions. Unlawful movement is an offence.	Reference only	Referenced-only	—	Primarily relevant to licensed warehouse operators. Reference only for a freight forwarder — applies transiently if Westlink takes temporary custody of customs-controlled goods (e.g. during transshipment under bond).
CUS-TTP-01	Customs Act 1901 s.176 + ABF Australian Trusted Trader programme	Voluntary programme recognising businesses with secure supply chains. Accredited Trusted Traders receive trade facilitation benefits (priority processing, deferred duty, reduced inspection rates).	Reference only	Referenced-only	—	Opportunity, not a duty. Worth evaluating once customs compliance baseline is established — Trusted Trader accreditation signals mature customs governance, complements DISP and JOSCAR-AU positioning. Defer until customs remediation packages (policy + screening + records) are delivered.
CUS-ADC-01	Customs Act 1901 Part XVB + Customs (International Obligations) Regulation 2015	Where imported goods are subject to anti-dumping or countervailing duty (dumping duty notice / countervailing duty notice), the importer must pay the applicable measure at the time of entry.	Reference only	Referenced-only	—	Applies only if Westlink imports goods subject to an active measure. Broker-managed in practice. Reference only unless own-account import profile includes relevant commodities (steel, aluminium, chemicals, manufactured goods — check Anti-Dumping Commission register).

Source document

Customs Act 1901 (Cth) + Customs Regulation 2015 + Customs (Prohibited Imports/Exports) Regulations — freight forwarder and consignor obligations

22 normative shall-statements extracted from Customs Act 1901 (Cth) + Customs Regulation 2015 + Prohibited Imports/Exports (source: Customs Act 1901 (Cth) + Customs Regulation 2015 + Customs (Prohibited Imports) Regulations 1956 + Customs (Prohibited Exports) Regulations 1958 + Autonomous Sanctions Act 2011 (reference) + Charter of the United Nations Act 1945 (reference)). The frontmatter requirements array is the source of truth — this body is rendered by scripts/render_compliance.py.

Coverage summary

Coverage	Count
✅ Full	12
🟡 Partial	3
🟠 Ref-only	6
🔴 Gap	1
— N/A	0

Gap severity distribution

Severity	Count
🔴 Critical	0
🟠 High	2
🟡 Medium	2
🟢 Low	0

Requirements

Clause Autonomous Sanctions Act 2011 + Autonomous Sanctions Regulations 2011

ID	Coverage	Evidence	Gap	Notes
CUS-SAN-01	✅ Full	[OPS-PRO-001 §‘§4 Sanctions Screening Control’](/wms/OPS-PRO-001#s’§4 Sanctions Screening Control’) [GOV-POL-023 §‘§Policy Statement’](/wms/GOV-POL-023#s’§Policy Statement’)

Clause Charter of the United Nations Act 1945 + UN Sanctions Regulations

ID	Coverage	Evidence	Gap	Notes
CUS-SAN-02	✅ Full	[OPS-PRO-001 §‘§4 Sanctions Screening Control’](/wms/OPS-PRO-001#s’§4 Sanctions Screening Control’) [GOV-POL-023 §‘§Policy Statement’](/wms/GOV-POL-023#s’§Policy Statement’)

Clause Customs Act 1901 Part VIII + Customs Tariff Act 1995

ID	Coverage	Evidence	Gap	Notes
CUS-IMP-03	✅ Full	[OPS-PRO-001 §‘§5 Customs Declarations and Valuation’](/wms/OPS-PRO-001#s’§5 Customs Declarations and Valuation’) [GOV-POL-023 §‘§Policy Statement’](/wms/GOV-POL-023#s’§Policy Statement’)

Clause Customs Act 1901 Part VIII Div 1A + FTA origin schedules

ID	Coverage	Evidence	Gap	Notes
CUS-ORI-01	🟡 Partial	[OPS-PRO-001 §‘§5 Customs Declarations and Valuation’](/wms/OPS-PRO-001#s’§5 Customs Declarations and Valuation’) [GOV-POL-023 §‘§Policy Statement’](/wms/GOV-POL-023#s’§Policy Statement’)	🟠 High	Control documented in OPS-PRO-001 §5 Customs Declarations and Valuation (rev 1). Coverage Partial — documented, not yet operationally exercised; residual is operational evidence (screening and declaration records) accruing from the next operating cycle.

Clause Customs Act 1901 Part VIII Div 2

ID	Coverage	Evidence	Gap	Notes
CUS-VAL-01	✅ Full	[OPS-PRO-001 §‘§5 Customs Declarations and Valuation’](/wms/OPS-PRO-001#s’§5 Customs Declarations and Valuation’)

Clause Customs Act 1901 Part XI (broker engagement by unlicensed forwarder)

ID	Coverage	Evidence	Gap	Notes
CUS-LIC-02	✅ Full	[OPS-PRO-001 §‘§5 Customs Declarations and Valuation’](/wms/OPS-PRO-001#s’§5 Customs Declarations and Valuation’) [GOV-POL-023 §‘§Policy Statement’](/wms/GOV-POL-023#s’§Policy Statement’)

Clause Customs Act 1901 Part XI (s

ID	Coverage	Evidence	Gap	Notes
CUS-LIC-01	🟠 Ref-only	—		Scope-setting row. Assumption: Westlink is not a licensed customs broker and engages licensed brokers as third parties for import/export declarations. Confirm operationally; if Westlink holds a broker licence, this framework scope must expand materially.

Clause Customs Act 1901 Part XVB + Customs (International Obligations) Regulation 2015

ID	Coverage	Evidence	Gap	Notes
CUS-ADC-01	🟠 Ref-only	—		Applies only if Westlink imports goods subject to an active measure. Broker-managed in practice. Reference only unless own-account import profile includes relevant commodities (steel, aluminium, chemicals, manufactured goods — check Anti-Dumping Commission register).

Clause Customs Act 1901 s

ID	Coverage	Evidence	Gap	Notes
CUS-REC-01	✅ Full	[GOV-SCH-001 §‘§4 Retention Schedule (International Freight and Customs Records)’](/wms/GOV-SCH-001#s’§4 Retention Schedule (International Freight and Customs Records)’) [GOV-POL-023 §‘§Records and Retention’](/wms/GOV-POL-023#s’§Records and Retention’)
CUS-REC-02	🔴 Gap	—	🟡 Medium	Electronic record-keeping controls for customs records not addressed. Integration with document management procedures (GOV-PRO-002, GOV-STD-001) is the remediation path.
CUS-IMP-01	✅ Full	[OPS-PRO-001 §‘§5 Customs Declarations and Valuation’](/wms/OPS-PRO-001#s’§5 Customs Declarations and Valuation’) [GOV-POL-023 §‘§Policy Statement’](/wms/GOV-POL-023#s’§Policy Statement’)
CUS-IMP-02	✅ Full	[OPS-PRO-001 §‘§5 Customs Declarations and Valuation’](/wms/OPS-PRO-001#s’§5 Customs Declarations and Valuation’)
CUS-IMP-04	✅ Full	[OPS-PRO-001 §‘§5 Customs Declarations and Valuation’](/wms/OPS-PRO-001#s’§5 Customs Declarations and Valuation’) [GOV-POL-023 §‘§Policy Statement’](/wms/GOV-POL-023#s’§Policy Statement’)
CUS-EXP-01	✅ Full	[OPS-PRO-001 §‘§5 Customs Declarations and Valuation’](/wms/OPS-PRO-001#s’§5 Customs Declarations and Valuation’) [GOV-POL-023 §‘§Policy Statement’](/wms/GOV-POL-023#s’§Policy Statement’)
CUS-EXP-02	✅ Full	[OPS-PRO-001 §‘§6 Export Controls — Defence and Strategic Goods’](/wms/OPS-PRO-001#s’§6 Export Controls — Defence and Strategic Goods’) [GOV-POL-023 §‘§Policy Statement’](/wms/GOV-POL-023#s’§Policy Statement’)
CUS-EXP-03	🟡 Partial	[OPS-PRO-001 §‘§5 Customs Declarations and Valuation’](/wms/OPS-PRO-001#s’§5 Customs Declarations and Valuation’)	🟡 Medium	Control documented in OPS-PRO-001 §5 Customs Declarations and Valuation (rev 1). Coverage Partial — documented, not yet operationally exercised; residual is operational evidence (screening and declaration records) accruing from the next operating cycle.
CUS-CGO-01	🟠 Ref-only	—		Cargo reporting is primarily the obligation of the vessel operator (master/agent) and the cargo reporter. Westlink as charterer is generally not the cargo reporter unless contractually assigned. Confirm charter-party arrangements. If Westlink is cargo reporter under any charter, re-scope this row to Applicable.
CUS-CGO-02	🟡 Partial	[OPS-PRO-001 §‘§5 Customs Declarations and Valuation’](/wms/OPS-PRO-001#s’§5 Customs Declarations and Valuation’)	🟠 High	Control documented in OPS-PRO-001 §5 Customs Declarations and Valuation (rev 1). Coverage Partial — documented, not yet operationally exercised; residual is operational evidence (screening and declaration records) accruing from the next operating cycle.
CUS-CGO-03	🟠 Ref-only	—		N/A —
CUS-CTRL-01	🟠 Ref-only	—		Primarily relevant to licensed warehouse operators. Reference only for a freight forwarder — applies transiently if Westlink takes temporary custody of customs-controlled goods (e.g. during transshipment under bond).
CUS-TTP-01	🟠 Ref-only	—		Opportunity, not a duty. Worth evaluating once customs compliance baseline is established — Trusted Trader accreditation signals mature customs governance, complements DISP and JOSCAR-AU positioning. Defer until customs remediation packages (policy + screening + records) are delivered.

Clause DFAT Consolidated List

ID	Coverage	Evidence	Gap	Notes
CUS-SAN-03	✅ Full	[OPS-PRO-001 §‘§4 Sanctions Screening Control’](/wms/OPS-PRO-001#s’§4 Sanctions Screening Control’) [GOV-POL-023 §‘§Policy Statement’](/wms/GOV-POL-023#s’§Policy Statement’)

Rendered from frontmatter by scripts/render_compliance.py. Source extraction: scripts/extract_iso9001_requirements.py. Evidence population: scripts/populate_iso9001_evidence.py. Validate: scripts/compliance_validate.py.