Substance trafficking in the supply chain

It will come as no surprise to service providers in international trade logistics and supply chain management that pathways, in whichever mode, provide significant opportunity for legitimate services to be used for illegitimate purposes. This can occur whether that be related to intellectual property, community health and safety, or the movement of dangerous substances across international borders. Service providers are therefore pivotal in ensuring, as far as possible, that their services are not the means of opportunity for the trafficking of dangerous substances. Service providers must maintain their own business imperatives, as well as support their respective communities, through regulatory oversight.

INCB Expert Group Meeting

Given its expertise in the process management of the international movement of goods, FIATA was invited to participate in an Expert Group Meeting (EGM) to address the trafficking of dangerous substance through international freight forwarding services. The meeting was organized online by the International Narcotics Control Board (INCB) of the United Nations from 30 November-11 December 2020, with 3-hour sessions spread over 5 working days.

In 2020, the INCB conducted an evaluation of movement pathways with the Universal Postal Union in relation to the movement of goods by post, in particular through the Express Mail System and the Global Express Alliance as to the movement of goods within the express carriage process. Following the evaluation, the INCB noted the gap as to the pathway on the international movement of goods in other modes, in particular with air and sea freight service providers.

FIATA participated with other experts from the public and private sectors to:

• discuss and examine lessons learnt from experience in responding to trafficking dangerous substances through the variety of pathways
• identify and propose possible collaboration as to ways to establish networks for cooperation as to industry exchange of information on dangerous substance trafficking, in particular to new psychoactive substances and nonmedical synthetic opioids and related precursors

These were addressed under a private-public partnership, under the concepts of:

• Manufacture (aims to promote governments’ cooperation with chemical and pharmaceutical manufacturers)
• Marketing (aims to promote cooperation with internet-related services including e-commerce platforms, social media, search engines, internet registries/registrars)
• Movement (aims to promote cooperation with postal services, courier services, and other logistics services including freight forwarders)
• Monetization (aims to promote cooperation with various financial intermediary services,   including credit card companies, international remittance services, and online financial intermediaries)

As to ‘movement’, it was clear in all circumstances that service providers rely entirely on the data and information provided by their respective clients and are not in a position to sight contents of consignments. Having knowledge of the shipper through appropriate identification is paramount. In this regard, the work by the British International Freight Association called A Guide to Due Diligence at an Individual Shipment Basis was cited as best practice.

Risk assessment can be conducted by taking steps in relation to knowing the shipper, critical ongoing review of the data provided by the shipper, early receipt of data and its provider for both private and public sector players. The opportunity exists for regulators to leverage off existing requirements in certain economies, as to air and sea freight preload requirements. In addition, aviation transport security requirements as to inspection in a variety of forms was noted as was the known shipper context.

Areas of focus

FIATA developed its presentation to the EMG around:

• The variety of players in international trade and its supply chain(s) adds to its complexity, and hence vulnerability
• The efficiency of the connectivity that attracts the interest of legitimate and non-legitimate users

Key issues discussed included:

• Business imperatives
• Good governance and compliance
• Legislative oversight
• Regulation/co-regulation/self-regulation
• Quality and timeliness of data
• Intelligence lead risk assessment
• Know the market     
• Association advocacy

There was a positive response from the INCB and EGM delegates as to the role and work of FIATA. In the future, FIATA plans on further enhancing its relationship with the INCB, as is the case with other United Nations agencies.