By a notice issued on 8^th May 2015, the Customs Agency implemented the EU guidance on the time bar nature of the three-year time limit under Article 221 of the Customs Code for the customs investigation; therefore, after three years from the customs operations, the administration will not be able to proceed with investigations and tax recoveries. An exception applies where failure to assess the correct duties originates from a fact that amounts to a crime: in this case, the three-year time limit has the nature of limitation and any delay in reporting the crime to the authorities over three years can only be raised by the taxpayer in the tax process. Failure to raise this defense will determine the validity of the customs assessment issued over three years after the completion of the import / export operations.