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The theory and practice of verification: The importance of accuracy and completeness
08/12/2022 04:53
It is of paramount importance for companies involved in anti-dumping and countervailing duty investigations to submit accurate responses to the Commerce Department. Foreign companies are at great risk if they submit inaccurate or incomplete responses. Errors of omission (for example, failing to disclose that a particular expense is incurred in the production or sale of the merchandise under investigation), are taken as seriously as errors in the accuracy of the information provided. In fact, errors of omission are perhaps even more likely to be considered a demonstration of 'wilful non-cooperation' by a foreign company, thereby justifying the use of an adverse inference in the application of 'facts available'. The most important step in a successful verification is therefore to submit an accurate and complete response.
