For the past decade or so, one of Cameroon Customs’ main priorities has been the enormous task of fighting illicit trade. Although it has been a regular participant in various crackdowns organized by the WCO in recent years, since late 2016 it has also been working on its own enforcement operation known as Operation Halcomi (short for “halte au commerce illicite [putting a stop to illicit trade]”).

Operation Halcomi was launched during the second half of 2016 in response to calls by a number of corporations and brands legally established in Cameroon, led by Guinness with its eponymous brand, Promodis with its brand Ovaltine, Boissons du Cameroun (known at the time as SABC) with its brand Heineken, and Nestlé Cameroon with its Nestlé-branded infant formula. These corporations were bearing the full brunt of unfair competition from illicit trade, since although they held exclusive contracts to advertise and distribute certain products within the country’s territory, they could only stand by and watch in incredulity while the local market was flooded with products which bore their brand names, but were of highly dubious origin and provenance. These fraud rings were so good at their job that, when one of these corporations contrived a phony shortage of its products, it was amazed to discover that its customers barely noticed the shortage, since they simply went on buying products that were identical in all but one respect – they had come across the border illegally from a neighbouring country.

After forming a partnership, the corporations in question then took the matter to Customs and asked it to consider embarking on synergistic activities to combat these imports, which contravened the laws and regulations in force. Several different types of fraud were identified:

• parallel trade, or in other words genuine goods imported into the country without a licence to import and/or distribute them there;
• fraudulent unloading of goods declared as being in transit towards neighbouring countries;
• imports of counterfeit products.

Customs responded to these calls by establishing a team of around 100 Customs officers under the auspices of a central command unit. The planned approach involved stepping up targeted checks and systematically recording all of the goods smuggled onto the market in Cameroon, compiling statistics, analysing the modi operandi of the fraudsters and tracing the lines of supply, all for the purpose of tracking down and holding accountable the perpetrators and instigators. With these goals in mind, the operational teams scrutinized the intelligence supplied to them – most of which came from the victim corporations – as well as networking with other defence and security forces, asking for support from local administrative authorities, and carrying out spot checks on strategic roads and certain border areas reported to be crossing points for the targeted products.

These measures quickly bore fruit. During the very first months of Operation Halcomi, several shipments of beverages bearing an internationally recognized brand and originating from a neighbouring country were seized in the south of the country (in the towns of Ambam and Kyé-Ossi). Shipments of chicken thighs and other foodstuffs, some of which were unsuitable for human consumption, were also seized in this area and destroyed in public by the competent authorities with a great deal of media hype, all for the purpose of raising awareness among the local population and those who might be tempted to become fraudsters themselves.

Over time, the goals pursued under Operation Halcomi have been extended to cover other major types of illicit trade, in particular prohibited goods (such as medications and medical consumables, counterfeit cosmetics, weapons and munitions, military hardware, hydrocarbons, narcotics, species protected by the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES), and certain chemical products and precursors likely to be dual-use substances). Operation Halcomi is now in its third phase, and its staffing levels have tripled.

The checks under Operation Halcomi have now been extended to cover all smuggled goods (i.e. goods that are not prohibited, but did not pass through Customs when being imported into the country). Vehicles are a goods category of particular interest to Operation Halcomi’s officers, who have benefited from an IT application known as COSMOS that was developed by the Information Systems Division and launched in early 2021. This application allows users to enter the chassis number of any vehicle on the road in Cameroon in order to check whether it was properly cleared by Customs when it entered the country.

Customs officers had noticed that, although an increasing number of high-end vehicles were appearing on the roads in Cameroon, the Customs Administration had no digital records of them passing through clearance. Although the majority of these vehicles had local number plates, for several years criminals had been smuggling them in across land borders which were too long to monitor effectively; the border with Nigeria alone has a length of around 1,900 km, for example.

The COSMOS application contains all of the data for vehicles which have entered Cameroon and been cleared by Customs since 1 January 2007. The officers carrying out checks under Operation Halcomi can simply use their mobile phones to log into COSMOS and enter the chassis number of the relevant vehicle to obtain its Customs status. It took only a few days from the launch of the COSMOS application for hundreds of vehicles to be seized throughout the country.

The application was then made available to the public, and a campaign was put in place to raise awareness. This campaign was such a resounding success and vehicle owners were so nervous about being picked up in checks that many of them verified the Customs status of their own vehicles and went to Customs of their own accord in order to formalize matters. To encourage this civic-minded attitude to Customs compliance, the Director General of Customs even announced a grace period during which anyone formalizing their vehicle’s status would not incur any fines.

Nearly eight years on, the results are broadly positive. As far as healthcare is concerned, Operation Halcomi has allowed the seizure of several tonnes of smuggled medicines and counterfeit medical consumables. Shipments of foodstuffs of dubious quality that were intended to be sold for human consumption have also been seized and destroyed. There have also been several high-profile seizures in the field of security, including 3,144 items of ammunition in 2024 and, in particular, 200 basic materials used for the manufacture of IEDs; this seizure, which took place in 2020, was a key factor in the decision by the country’s highest authorities to integrate Customs into the national defence and security community. As regards environmental and ecosystem protection, several tonnes of non-biodegradable plastics have been seized, as well as species protected under CITES.

Operation Halcomi officers specifically tasked with securing the sea borders furthermore seized several tonnes of smuggled fuel from the south-west of the country, where various separatist groups have set themselves up in opposition to the state since 2017.

Finally, efforts to recover unpaid duties and taxes have delivered a substantial return, and civic-mindedness has been encouraged in this area due to the fear of crackdowns. Over the past four years (2021-2024), Operation Halcomi has prepared 5,338 files for litigation, accounting for almost 12% of all enforcement measures by Customs. These litigation activities have made it possible to recover 5,306,069,591 CFA francs (around 7.8 million euros) in evaded duties and taxes, and to collect 2,620,874,622 CFA francs (around 3.8 million euros) in fines.

Operation Halcomi’s success depends on a number of different factors and advantages.

The first of these is that the staff deployed under Operation Halcomi are selected with the utmost of care. The heads of “traditional” Customs units are obliged to accept into their staff anyone who has been recruited to the civil service and assigned there, but the central command unit of Operation Halcomi is able to set stricter selection criteria. A list of pre-screened candidates is normally submitted to the Director General of Customs, who then issues a memorandum indicating that these candidates are available for secondment to Operation Halcomi. Any new recruits who do not (or who no longer) live up to the central command unit’s expectations after a given period of time are assigned back to their original unit. Operation Halcomi has thus become an elite group gathering together the best officers from units throughout the country, including all of its regions and its land, sea and air borders.

A further unique feature of Operation Halcomi is its specialized nature. The heads of the traditional Customs units often spend more than half of their working hours on administrative and external representation tasks which make no difference to enforcement outcomes. The Operation Halcomi officers and those in charge of these latter can devote all of their time, energy and ingenuity to tracking down illicit trade, using approaches such as collecting and deploying intelligence, implementing shadowing measures, infiltrating fraud networks and exchanging information with defence and security forces.

One key advantage is the partnership that has been established with companies and economic operators, since these latter often provide Customs with valuable insights into certain areas of fraud and illicit trade. Some also assist Customs by providing training on their products and brands so that officers can more easily identify fakes.

A further unique feature of Operation Halcomi is that its officers partition up the entire country between them and therefore work on a nationwide basis. The traditional Customs units are limited to working in the areas they control; they often fail to coordinate measures and exchange information systematically, and sometimes even clash with each other over matters relating to competencies and leadership. Under Operation Halcomi, the country is divided into three large areas that cover the 12 existing Customs sectors: Halcomi Zone I (Customs sectors Coast 1, Coast 2, South-West, North-West and West), Halcomi Zone II (Customs sectors Centre, South 1, South 2 and East), and Halcomi Zone III (Customs sectors Adamawa, North and Extreme North). One coordinator, assisted by a manager of operations and a spokesperson, is in charge of each of these Operation Halcomi areas. One bonus of splitting the country up into large areas in this way is that the response to illicit trade can be planned more efficiently.

Last but not least, a further benefit relates to a streamlining of the chain of command. Operation Halcomi’s officers do not sit at the bottom of a tall hierarchy like their counterparts in the traditional Customs units, since the coordinators of the three areas report directly to and receive instructions from the central command unit. Given the highly transient nature of fraudulent activities, this responsive decision-making structure is probably the biggest factor in the operational success achieved to date. Equally, Operation Halcomi’s officers benefit from working outside the purview of the heads of local Customs units because this often makes them more daring and persistent in tracking down and punishing fraudsters with whom a compromising familiarity has often developed at local level over time.

Operation Halcomi has been the subject of a number of minor and major criticisms. The first of these relates to its length, since some believe that a special operation should only run for a limited period. Although this is broadly true, it is important to remember the ultimate purpose of the measures implemented by Customs. If the services responsible for monitoring the movement of goods are interested in achieving operational efficiency, it would be obtuse, not to mention counterproductive, to sacrifice this efficiency on the altar of purely formal constraints relating to the length of a mission.

A further criticism that has long been voiced relates to the tendency for Operation Halcomi’s officers to call into question – almost systematically – the work carried out by traditional Customs units. According to some reports concerning roadside vehicle checks, Operation Halcomi’s officers consistently challenged the values that had been declared during clearance, and the vehicle owners were unable to understand how the same Customs administration could issue a certificate approving the Customs clearance of a vehicle one day, and then the very next day send out its officers to dispute this very same assessment. With a view to rectifying these failings, in October 2022, Operation Halcomi’s central command unit told its officers to confine themselves to checking that the Customs clearance procedure had been completed and not to question the details, since there was a different, specialized department with specific responsibility for handling said details. These instructions were reiterated in even clearer and more forthright terms by the Director General in March 2024.

Finally, mention should be made of a number of ways in which Operation Halcomi could be fine-tuned to make it even more efficient. The first involves stepping up cooperation with companies that have fallen victim to illicit trade, since Operation Halcomi – as noted above – was initially put in place in response to calls by these companies, with the primary aim of responding to specific challenges and difficulties they were facing. As time has gone on, however, cooperation with these companies has grown weaker, leading to a sense that Operation Halcomi has deviated somewhat from the true priorities and concerns of its beneficiaries. When viewed from this perspective, Operation Halcomi could be made even more efficient and its performance even more convincing if it concentrated on certain tariff lines or Customs procedures for a set period of time (for example special missions targeted at medicines, alcohol or cooking oils, or at procedures such as transit, temporary importation and public works machinery).

Finally, in the area of trade facilitation, Operation Halcomi should devote more attention to the problem of long border crossing times for containers, particularly at ports. Since the latter are intrinsically subject to a higher level of surveillance and any goods passing through are routed via Customs offices, it would be advisable to use intelligence as a basis for carrying out checks instead of encumbering users with multiple checkpoints. The focus should be on smuggled goods and the routes along which they are smuggled (coves, land borders and bodies of water), and it might be preferable to inspect suspicious goods transported in containers at their final destination rather than holding up multiple containers at ports or en route to the facilities where they are emptied, since this would reduce border crossing times and avoid demurrage charges.

The final point relates to human resources, since Operation Halcomi’s officers should receive more training so that they are better able to support companies. As part of the stepping up of cooperation with these companies, more training sessions should therefore be organized in order to ensure that officers are more easily able to identify fakes. Finally, Operation Halcomi’s central command unit could make recruitment to or continued membership of this elite group dependent on completing certain training modules or supplying evidence that these modules have been completed via the WCO’s CLiKC! platform.

More information
cab.douanes.cameroun@gmail.com
Serge Tepiele