Fighting illicit trade: an overview of the WCO’s contribution
30 October 2024
By Ian Saunders, WCO Secretary GeneralThe first time that any authority attempted to put an obstacle in the way of humans moving goods or themselves across territory by imposing restrictions, borders, and Customs controls, illicit trade was born, explained journalist and writer Moisés Naím while presenting his latest book.[1] Many scholars also point to today’s relations between illicit traders and the state as “simply the latest stage in an age-old process, even as forms of social tolerance, forms of smuggling, regulatory norms, demand, and the nature and types of activities may have changed over time”.[2]
Naím and other observers are, however, stating that such movements have acquired a new dimension – they are now global – and have different consequences, undermining legitimate markets, eroding public trust, and funding criminal enterprises. In short, they are transforming global politics and economics.
Against such a backdrop, law enforcement agencies are asked to do more with less, to develop strategies and solutions as dynamic and adaptable as the problem itself. There is near-universal recognition that, to combat illicit trade, they must coordinate their actions and take international initiatives based on collective knowledge and experience.
Since the creation of the World Customs Organization in 1952 and its Enforcement Committee in 1984, WCO Members have been discussing ways to identify, stop and prevent illicit trade. From a very early stage, supported by the Secretariat, they developed data and information catalogues, exchanged information on the use of equipment and technologies and organized exhibitions. They also prepared model training courses and made video recordings of training sessions, delivered seminars, exchanged experiences, shared targeting techniques, collected best practices and developed handbooks and legal instruments. Much of this work has remained fundamentally the same, although the implementation of new technologies has totally transformed the way it is conducted.
Awareness-raising and training
Allowing for effective enforcement necessitates a certain level of well-functioning Customs structures and the use of efficient working methods based on intelligence analysis and risk profiling. The WCO has established several programmes focusing on specific commodities or issues such as drugs, the environment or security. Capacity-building activities under these programmes include conducting assessments and diagnostics, preparing work plans, providing training and engaging stakeholders. They all place an emphasis on building partnerships, strengthening Customs’ overall intelligence analysis capability and using technologies. Administrations receiving WCO support play an active role in these activities and are asked to take ownership of the recommendations drafted in consultation with experts.
These experts also contribute to initiatives led by other international organizations. For example, the WCO recently became a member of the Plastic Waste Partnership established under the Basel Convention with the aim of mobilizing resources and expertise from business entities, governments, academia and civil society organizations in order to improve and promote the environmentally sound management of plastic waste. Its experts contributed, among other things, to developing and undertaking training on the implementation of the amendments to the Convention on plastic waste and to the development of fact sheets on WCO Harmonized System (HS) codes for plastic waste.
Multi-agency teams
Several initiatives whose core aim included the development of enforcement capacities at specific ports and airports through the establishment of multi-agency teams have been merged into a single programme called the Passenger and Cargo Control Programme (PCCP) which is co-managed by the WCO and the United Nations Office on Drugs and Crime (UNODC).
Three types of units that bring together Customs officers and representatives of other enforcement agencies have been established under the programme: Port Control Units (PCUs) which are operational in 113 ports in 86 countries; Air Cargo Control Units (ACCUs) which have been established in 23 airports; and Joint Airport Interdiction Task Forces (JAITF) which have been set up in 36 countries.
Enforcement operations
Other key WCO activities include enforcement operations. Administrations participating in such operations are requested to share data on seizures of targeted commodities and on suspicious transactions in real time using the CENcomm, the WCO’s secure, web-based communication system. In order to prepare for an enforcement operation, officers usually receive a combination of classroom-based and hands-on training. Once an operation is over, the results are analysed to create a snapshot of the trends and patterns used by smugglers and capture a sense of the scale of illicit trade and its wider impact.
Among the many operations carried out annually are Operation Thunder, which focuses on illegal wildlife and timber trade; Operation Demeter, which focuses on waste and substances controlled under the Montreal Protocol; Operation Arena Blanca, which deals with explosive precursors and other material used to construct or transport improvised explosive devices (IEDs); and Operation Stop, which targets IPR infringements in the areas of pharmaceuticals, vaccines and medical devices, as well as everyday consumer products that pose a risk to health and safety.
Following the “Guidelines on the implementation of WCO operations at national level”, administrations participating in these operations are usually requested to conduct trade and threat analyses, draft national implementation plans and risk profiles, identify other government agencies to join the operation, conduct training, set up joint control units at selected border points wherever possible, and establish a national contact point (hub) consisting of representatives of all partner agencies. Accordingly, such operations enable these administrations to take stock of their capacity to carry out efficient controls and to work with their counterparts to that end. These operations also enable administrations to learn from one another’s strategies and experiences, to share information such as modi operandi or to test the use of specific technologies, among other things.
Information management
To enhance Customs’ data mining and risk analysis capacities, the WCO developed an application called the National Customs Enforcement Network (nCEN). This application gives Customs administrations the ability to collect, store, analyse and disseminate law enforcement data effectively at the national level, with the additional possibility of exchanging this information at regional and/or international levels.
Another application is the Cargo Targeting System (CTS), a system which makes it possible to gather and store electronic cargo manifest, bill of lading and air waybill data and which provides users with an interface that allows them to search and analyse those documents by applying consistent risk indicators, generated from risk profiles and watch lists, to all cargo consignment records.
In 2023, an impact assessment questionnaire was circulated among those Members that had implemented these applications in an effort to gauge how successful these tools have been in supporting risk management activities. The results show that, although the application has proven effective in enhancing certain aspects of Customs operations for some administrations, the overall impact across all surveyed countries has been mixed. Issues faced by administrations range from technical difficulties to training gaps hindering effective use of the tools. The Secretariat is currently working to address the reasons behind the lack of reported successes and addressing technical issues experienced by Members.
Sharing operational information and connecting experts
Several closed user groups (CUGs) have been set up in CENcomm. They aim at enabling information exchange on illicit trade and smuggling activities and/or the sharing of information of interest to field officers and analysts. CENcomm has also been leveraged to create specialized libraries, such as the Vehicle Concealment Library (CAVA) which contains photos, videos and written documentation about detected concealments in all kinds of vehicles. Some groups are open to other law enforcement agencies, NGOs or private entities. The focus of and user profiles for the respective groups have been described in a previous article published in WCO News. It is worth noting that a Global Image Concealment Database (GICOD) has been created since the publication of that article.
Enhancing data collection for risk analysts
The Customs Enforcement Network (CEN) is, at its core, a database of seizures and offences as well as pictures required for the analysis of illicit trafficking in the various areas under Customs’ competence. In 2023, a cutting-edge data visualization solution was integrated into the CEN to provide Members with an instant and comprehensive overview of illicit trafficking trends through graphical representations of CEN data sets. Users can also filter and analyse seizure data, including on the different means of transport and concealment methods used.
When the first discussions on the creation of the Customs Enforcement Network began in the Enforcement Committee in 1999, there was agreement that the CEN would have positive implications for the organization of Customs enforcement services around the world and a common understanding that the implementation and success of the project would depend on all parties being willing to share information in a timely and secure manner. However, the collection of data in the CEN has historically faced several challenges, including inconsistent data submission rates and concerns over data quality.
It is in this context that the “WCO Charter of Data Quantity and Quality Enhancement in the CEN” was adopted in June 2021, as a fundamental strategic commitment of WCO Members and the WCO Secretariat to enhance data submission to the CEN. Two of the principal measures taken as a result of the Charter were the implementation of the CEN Simplified Input Form (SIF) and the creation of a desktop application. The SIF was designed to collect a smaller data set, and the desktop application was developed to address the challenges of data entry in areas with unstable internet connectivity. The development of these solutions was a significant step towards addressing the technical barriers that previously hindered efficient data submission.
Promoting the Charter and building the capacity of Members to use the CEN applications through national and regional training sessions led to a record number of entries in 2023. In addition, 10 countries entered data into the CEN for the first time since 2020. The analysis of this data can be found in the Illicit Trade Report 2023 which was released in June this year.
New training and guidance material
Courses developed by the WCO through its various programmes and projects cover a wide range of domains (wildlife, drugs and precursors, IPR, substandard and falsified medical products, plastic and hazardous waste, strategic goods, cash, explosive precursors, radioactive material, small arms and light weapons, etc.), threats (insider threats, free trade zones, air fast parcel delivery, mail parcels, etc.) and techniques (scan image analysis, practices related to enforcement and seizures, evidence collection, intelligence gathering and analysis, use of open-source intelligence, digital forensics, controlled deliveries, enforcement operations planning, etc.).
Most recently, the WCO developed a number of e-learning modules that introduce Customs officers to geospatial intelligence (GEOINT) and demonstrate how it can be used to assist Customs in managing national borders in remote regions.
In terms of guidance material, we continue to update the Risk Management Compendium, with drafting groups working on sections related to data analysis, international postal streams and insider threats. The Compendium is currently available in PDF format and is over 800 pages. To enhance the user friendliness of the Compendium, the WCO is currently working on a web format.
A study report entitled “Unlocking the Value of Open-Source Intelligence (OSINT) in Customs Enforcement” has also been released. Designed for senior management within Customs administrations, it provides insights into how Customs administrations can utilize OSINT to strengthen their enforcement efforts, offering practical advice on integrating OSINT within Customs administrations.
Finally, the WCO has developed standard operating procedures (SOPs) for waste shipment controls to provide Customs administrations with a methodology for developing domestic SOPs for controlling waste shipments through a comprehensive set of templates.
Dossier contents
For this edition of the magazine, we asked several Customs administrations and organizations to share their experience in combating illicit trade.
In the first article, US Customs and Border Protection (CBP) explains how it intensified its efforts to prevent pork products originating from countries affected by African swine fever from entering the US. CPB officers found that individuals are working collectively across the US to bring such products into the country, creating networks not unlike those used for smuggling narcotics or counterfeits.
Next is an article by the Nigeria Customs Service (NCS) that explains how, in a few years, the Service changed the narrative when it comes to wildlife trafficking, from being “a toothless dog”, with no seizure or arrest on record, to the “new sheriff in town”. The author highlights that the work done by the WCO to raise awareness and train Customs officers in this area has had a tremendous impact in Nigeria and that the NCS is even now engaged in the work of the Organization to support other Customs administrations.
This is followed by an article by Argentine Customs on the strategy it has adopted to enhance its capacity to enforce intellectual property rights. Among other measures, it has introduced an IT tool called “Sistema de Asientos de Alerta”. Its functioning is difficult to describe in just a few words, so I would highly recommend reading the article to find out more.
An article by Mauritius Customs then looks at the fight against drug trafficking, giving an overview of the enforcement arsenal deployed by its Administration and highlighting some success stories.
This leads on to an article on controlling general aviation (GA) in which the Argentine and Senegalese Customs Administrations describe progress made under the WCO COLIBRI Project. In particular, they explain the project’s impact in raising awareness among Customs officials and other law enforcement authorities of the threat posed by GA, capacities for combating fraud and transnational organized crime, the level of interinstitutional and international cooperation, and the role of Customs in ensuring coordination among the security forces.
It is then the turn of Irish Customs to provide an account of work undertaken by its training team to revisit instruction in vehicle search procedures during the COVID-19 pandemic. By leveraging both public and private partnerships, they succeeded in developing a training course which participants qualified as “superb”, “innovative”, “special” and “inclusive”.
We then delve into the use of analytics tools and real-time monitoring technology, with an article by Brazil Customs. Although some of the tools presented in this article are designed to detect commercial fraud, others were developed to support the fight against illicit trade by enabling, for example, the monitoring of vehicles near land borders or the automation of the analysis of scanned images.
The next article, by China Customs, also addresses the use of advanced analytics. It gives an overview of the Administration’s efforts in leveraging big data to enhance its capacity to detect fraud and illicit trade.
In the final article in the Dossier, the French and Benin Customs Administrations then present the Borders Academy which is being set up in Benin to train the armed forces that intervene in the border areas – police officers, officials from the forestry and Customs services and members of the defence and security forces – to enable them to act in a coordinated manner to counter the various armed groups that are active in the region and to dismantle illicit networks, while protecting local communities and building mutual trust.
I trust that you will enjoy reading this Dossier and the other sections of this latest edition of the WCO News magazine. I offer my sincere thanks to all the contributors who have taken the time to share their thoughts and experiences with us.
[1] Moisés Naím, lecture about the book Illicit: How Smugglers, Traffickers and Copycats Are Hijacking the Global Economy, delivered at the Inter-American Development Bank in Washington, DC, on 6 December 2005.
[2] Paul Kemp, Rebecca Galemba, Illicit Trade and Smuggling, 28 October 2020, consulted on 10 September 2024.