For global shipping lines, it is crucial that the responsibility to investigate and do law enforcement lies with the authorities. Our key priority is to prevent and protect our employees and our customers’ supply chains. However, shipping lines can and should play a role in the work identifying and managing risks in close collaboration with the authorities. At Maersk, a risk management approach is applied to daily operations. And our experience shows us that tangible results can be made in public-private partnerships and builds a foundation for further action. This article discusses how a strategic approach adopted by Maersk can help strengthen the illicit trade prevention work.

A recent case in one European port illustrates this approach: a shipment of illegal waste declared as low-grade metal was stopped by the company prior to being loaded on a vessel to enable the authorities to carry out an inspection. The shipment had been flagged by Maersk risk management system, which systematically analyses a wide range of data to identify inconsistencies or anomalies in classification, value, quantity, description or routing.

Maersk uses mirror statistics and data reconciliation as an upstream risk intelligence tool to identify discrepancies at an aggregate level across trade lanes, commodities, and trading partners that may signal elevated compliance risk. In practice, this involves combining publicly available trade data – such as UN COMTRADE and national statistical sources – with internal shipment-level information using a number of multiple data elements and information sources to construct a comparative view of expected versus observed flows.

On top of this, external intelligence is incorporated, including inputs received through cooperation with Customs authorities, law enforcement agencies, industry associations, and rights holders. Such partnerships are critical, as they provide context that cannot be derived from internal data alone, particularly with regard to emerging trends, known high-risk actors, or newly identified typologies.

Advanced analytics are applied to these combined datasets to support systematic risk identification. Risk-scoring models are used to flag shipments that exhibit unusual characteristics of different kinds.  These models are continuously refined through feedback loops: cases that are confirmed through inspections made by authorities (as shipping lines have very limited powers and options to do that), or external reporting are reintegrated into the system, allowing the models to learn and improve over time.

Equally important, however, is the role of professional judgement. Automated systems provide prioritisation, scale and alerts to patterns, but decisions – such as placing a shipment on hold or escalating a case – are ultimately taken by experienced professionals who assess the full context of each situation.  This interaction between data-driven tools and human expertise is central to ensuring that risk management remains both effective and proportionate.

Over time, mirror analysis and data reconciliation in Maersk system has helped to highlight a number of recurring modus operandi. One of the most common issues is incorrect or incomplete product descriptions, not allowing to properly check the actual character of goods. Discrepancies may also point to routing strategies designed to obscure origin, such as the use of intermediary countries that are not economically justified by the underlying trade. Some other data analysis can further help indicate attempts to exploit gaps in monitoring systems. These patterns are not assessed in isolation: they are cross-checked against other relevant data and transaction-level data to determine whether they reflect legitimate commercial activity or warrant closer scrutiny.

The risk management model combines central oversight with decentralised execution. Overall direction, methodologies, and risk frameworks are defined by a global team at headquarters, which ensures consistency in how risks are identified, assessed, and escalated across the organisation while also reducing risk for frontline employees. This central function works closely with regional and country-level specialists who apply these frameworks in their respective operational contexts, taking into account local regulatory environments, trade patterns, and enforcement priorities. Such dual structure allows for both standardisation and flexibility: risks are approached through a common lens, but decisions remain informed by proximity to operations.

Illicit trade prevention is not concentrated within a single multidisciplinary team but is delivered through a combination of specialised units with distinct roles. The Special Operations team serves as the primary law enforcement arm, working cross-functionally to detect, investigate, and escalate potential illicit trade cases, with support from the Compliance team where regulatory interpretation or escalation is required. In parallel, Customs Services ensures the compliant execution of routine customs clearance for Maersk’s clients, embedding regulatory adherence into day‑to‑day operations and reducing baseline risk across the supply chain. Across these functions, expertise remains multidisciplinary, drawing on backgrounds in customs, logistics, data analysis, and enforcement, enabling both proactive risk mitigation through compliant processes and reactive intervention through targeted enforcement actions.

When suspicions are sufficiently substantiated, Maersk engages in structured cooperation with Customs authorities and other competent bodies. This cooperation takes place within clearly defined legal and data protection frameworks, and typically involves a combination of operational and informational support. Relevant data and observations can be shared with authorities to support their risk assessments and investigative work, where permitted by law. It is important to underline that Maersk’s role remains preventive: the company does not investigate individuals or enforce the law, but takes action to protect its people and operations.  This distinction is essential to maintaining both legal clarity and the security  of employees.

Close cooperation and mutual trust between the private sector and Customs administrations are therefore critical to the effectiveness of this approach. Mirror analysis, when combined with operational data and intelligence sharing, creates a form of common analytical ground on which both sides can operate.

Maersk already has strong, productive, and daily interactions with many Customs administrations around the world. Yet we can still further improve our network and work together to realise the full potential of our approach via public-private collaboration. A key game changer for shipping lines would be improved access to timely, granular, and reliable trade data, as well as greater interoperability between public and private sector systems. While significant progress has been made in digitalisation, data remains fragmented across jurisdictions and institutions, often limiting the ability to form a complete picture of trade flows for more powerful data analysis.

Further advancements in secure data sharing mechanisms, clearer legal frameworks for public – private cooperation, and continued investment in digital infrastructure would significantly enhance the capacity to detect and prevent illicit trade. For shipping lines and their clients, this would mean being able to identify risks earlier and with greater precision. For Customs authorities, it would provide additional, actionable intelligence to support enforcement. Ultimately, strengthening these connections would not only improve compliance outcomes, but also contribute to the integrity and resilience of global supply chains more broadly.

Cooperation with external stakeholders is organised across specialised teams with distinct mandates but shared objectives, including protecting customers, supporting compliant trade, and ensuring smooth global supply chains. While Maersk Customs Services engage with authorities on customs clearance, trade facilitation, and regulatory matters, when it comes to cooperation on illicit trade prevention it is Maersk Special Operations team that is the central point of contact for all enforcement-related activities. This structure enables effective dialogue, information exchange, and coordinated action across trade and supply chain security.

More information
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