Following the 11 September 2001 terrorist attacks, the United States government formulated and implemented national security policies to, among other things, augment domestic protection and reduce fear from the threat of violent extremism. Many other governments followed the same strategy, all adding and prioritizing national security to the existing portfolio of policy objectives for their Customs services.

These policies broadly consisted of expanded trade data submission requirements for economic operators early in the supply chain; enhanced risk management methods geared to security; increased use of non-intrusive container cargo scanning; and the introduction of security-oriented compliant and validated trader benefits policies.

To ensure a minimum level of harmonization, the World Customs Organization (WCO) adopted in 2005 an international Customs instrument for supply chain security called the WCO SAFE Framework of Standards to Secure and Facilitate Global Trade (WCO SAFE Framework). The SAFE Framework “embodies the notion that the new mission of security has shifted the focus of Customs from its traditional place of import to encompass the entire trade supply chain that covers the movement of goods from origin to destination”[1].

Monitoring and oversight of suppliers

Among other things, the SAFE calls for each Customs administration to “establish a partnership with the private sector in order to involve it in ensuring the safety and security of the international trade supply chain.”[2] These trusted business partners, that should receive tangible benefits in such partnerships in the form of expedited processing and other measures, are to be identified through a certification system at the end of which they can join what is generically called an Authorized Economic Operator (AEO) programme.

The first of such programme, which preceded and inspired the AEO concept, was the US Customs-Trade Partnership Against Terrorism (CTPAT). US importers wishing to join the partnership had not only to prove that they met certain criteria, but also to comply with business partner monitoring and oversight obligations.

To do so, importers had to allocate important resources to auditing activities. As for transporters, suppliers and manufacturers, they soon started complaining about the repetition of supply chain security audits conducted by these CTPAT importers. In 2014, united by the same grievance, US and Canada based importers hold talks to identify a strategy to reduce costs and the number of such audits conducted on suppliers and factories.

They created the Supplier Compliance Audit Network (SCAN) as a not‑for‑profit alliance and devised a system based on:

• a single standard aligned with the CTPAT and the WCO’s Authorized Economic Operator concept.
• two membership status: executive membership for direct importers who are current members of CTPAT or of any AEO programme recognized by the United States under a mutual recognition arrangement; and associate membership for manufacturers, transportation and logistics providers.
• a governance model built on independence, impartiality, and the avoidance of conflicts of interest: SCAN works with seven global accredited auditing companies; their auditors remain independent from membership decisions, preventing any individual or group from occupying a dual role that could compromise impartiality.
• Annual revalidation: most audits are reconducted annually, ensuring continuous accountability, real‑time visibility into supplier performance, and a living compliance environment rather than a multi‑year snapshot.
• a secured blockchain: documents related to audits are exchanged and recorded on a blockchain to ensure immutability.
• A secure, trusted online platform where auditing results are published and shared with executive members (importers).
• A training programme to ensure consistent understanding of standards, corrective actions, and emerging regulatory requirements among members.

Because many SCAN importer members share suppliers, this results in lower costs for the supplier. Moreover, as importers collectively – but independently – monitor suppliers, they promote a culture of compliance that often extends beyond regulatory requirements.

Finally, preliminary data from CTPAT importers who are also members of the SCAN Association shows that entities validated through SCAN become lower‑risk actors in Customs and Border Protection (CBP) risk engines.

This should not be a surprise.  After all, in April of 2024, U.S. Customs and Border Protection and the SCAN Association signed an agreement which established 11 objectives or areas of cooperation, including:

• The Recognition of a SCAN Audited Business Partner – When a CTPAT member has a SCAN audited business partner as part of its supply chain, such as a manufacturing facility overseas, the CTPAT member only needs to document to its CTPAT Supply Chain Security Specialist that this business partner is SCAN certified in order to meet its CTPAT business partner monitoring and oversight obligations.
• CBP Access to the SCAN Association’s Audit Repository – The SCAN Association agreed to provide CBP personnel with access to its repository of supply chain security audits. CTPAT Supply Chain Security Specialists, Intelligence Analysts, Import Specialists, and personnel from the National Targeting Center use this repository to gain additional assurance regarding the integrity of a specific supply chain or shipment entering the United States. A facility that has undergone a SCAN audit represents a lower‑risk entity and provides CBP with independent confirmation that the site exists and has been assessed against CTPAT’s security criteria.
• Sharing of information between the two organizations to institutionalize information-sharing arrangements.

In an era of friend‑shoring, sanctions, and geopolitical volatility, SCAN strengthens trusted trade corridors by validating upstream manufacturing and enabling near‑shoring strategies. Through independent validation, standardized criteria, digital trust mechanisms, and governance integrity, SCAN provides USCBP with assurance that audits on foreign based suppliers are rigorous, consistent, impartial and technically credible.

SCAN is becoming a force multiplier for managing and reducing supply chain threats at scale. With global membership expansion underway, new partnerships forming with Customs administrations to support their AEO programmes, and the launch of our social compliance audit planned for late 2026, SCAN is strengthening its role as a credible, unified solution for secure and responsible sourcing.

More information
Contact the author

[1] https://www.wcoomd.org/-/media/wco/public/global/pdf/topics/research/research-paper-series/18_cscsp_911.pdf?la=fr

[2] https://www.wcoomd.org/-/media/wco/public/global/pdf/topics/facilitation/instruments-and-tools/tools/safe-package/safe-framework-2025_en.pdf?la=en