Policy & Compliance
Due diligence – a reminder Due diligence and mitigating strategies are becoming increasingly important to business and the range of subjects covered seems to be ever expanding
T he recent £450 million haul of cocaine follow good practice to ensure the compliant movement of cargo. The humble seafreight container has solved many problems and encouraged global trade, but it has also facilitated a growth in concealment. BIFA has recently noted an increase in the number of calls concerning cargo crime; however, in the UK cargo crime is often not reported separately from similar offences. For instance, theft from a vehicle is often reported simply as ‘vehicle crime’ and there is no appetite amongst the authorities to change the current situation. At BIFA, the complexity of the supply chain is fully appreciated, as is the difficulty in conducting due diligence checks. This is exacerbated by the lack of meaningful information available in some government databases. Members should note that it is not just crime that is a major threat; Customs related non- compliance and the avoidance of sanctions and export controls all remain significant issues. All too often the BIFA Member has to deal with the transhipping Southampton has highlighted the need for all participants within the supply chain to
problems of abandoned cargo when it has been deliberately undervalued. When HMRC uncovers this or similar non-compliance the importer will, on occasion, disappear leaving the Customs agent with cargo that no one wants. The Customs agent has the awkward and sometimes expensive task of surrendering the goods to the Crown. There is an increasing tendency in the UK for government to make the freight forwarder/Customs agent responsible for conducting checks to verify client and shipment-related information. HMRC recently issued guidance on the Customs agent’s responsibility to confirm values on consignments over £20,000 and retain evidence that they have done so. Many would argue that this places the Member, when undertaking Customs work, in an impossible position. ‘Know your cargo’ BIFA has consistently advised its Members to ‘Know your customer’ and more recently in our good practice guide we look at due diligence at an individual shipment basis – scan the QR code (left). In other words, ‘Know
Individual shipment
14 | May 2024
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