facilitating trade: improving customs risk management
TRANSCRIPT
Facilitating Trade:
Improving Customs Risk Management Systems in the
OIC Member StatesOIC Study 2018
11th Meeting of the COMCEC Trade Working Group
1
The presentation is specially prepared for the 11th Meeting of the COMCEC Trade Working Group
Objectives and Methodology of the Study 1
Benchmark Criteria of the Study 2
Main Findings – Analysis Results 3
OIC Case Studies 5
OIC MS CRM Challenges / Policy Options 6
Non-OIC Case Studies 4
2
Objectives and Methodology of the Study 1
Benchmark Criteria of the Study 2
Main Findings – Analysis Results 3
OIC Case Studies 5
OIC MS CRM Challenges / Policy Options 6
Non-OIC Case Studies 4
3
4
Desk Research‣ Literature Review
‣ Review Trends in
CRM Experiences
Globally
‣ Locate and Analyze
CRM Systems in
Three Non-OIC
Countries
‣ Develop Lessons
Learned and Critical
Success
Factors/Challenges
‣ Survey creation and
dissemination
‣ Collection,
systematization and
analyzing of the
statistical data from
internationally
available databases
‣ To document the
current status of CRM
systems in the OIC
MS and develop
benchmarking criteria
‣ Face-to-face
interviews with
representatives from
CAs
‣ Identify the major
steps necessary to
achieve an efficient
and effective CRM in
these countries
‣ Draw a series of
conclusions and for
further improvement
of CRM across the
OIC member states
‣ Analyzing by different
statistical tools as
descriptive statistics
‣ Compare different
variables and
correlation analysis
‣ Find the influence of
different aspects of
CRM development in
OIC MS with trade
costs, country
rankings related to
trade facilitation
Desk
Research
Data
Collection
Data
Analysis
Field Visit
Case Study
1. Methodology and Objectives of the StudyMethodology of the Study
5
• To improve awareness of the CRM and the benefits it produces for the trade facilitation
• To share information on the best practices of CRM implementation
• To explore the state of play of CRM in the OIC countries, including CRM implementation, performance and trade facilitation impacts, and
• To provide policy options and guidelines for establishing/improving effective CRM.
1. Methodology and Objectives of the StudyObjectives of the Study
6
Introduction 1Conceptual Framework 2Global Trends and Best
Practices 3
Analysis of the CRM
Implementation Stage 4Assessments in 3 OIC
Member Countries 5Conclusions and
Recommendations 6
1. Methodology and Objectives of the StudyThe Sections of the Study
Objectives and Methodology of the Study 1
Benchmark Criteria of the Study 2
Main Findings – Analysis Results 3
OIC Case Studies 5
OIC MS CRM Challenges / Policy Options 6
Non-OIC Case Studies 4
7
‣ Customs Code,
Implementing
Regulation and
Customs
Strategy
‣ Law Enforcement
and CRM
Strategy/Policy
‣ Action Plan and
KPA
‣ MMA and MoUs
‣ Implementation
of International
Standards and
Agreements
Supporting
Mechanism
‣ Organizational
Structure Support
of CRM
‣ Change
Management and
Continuous
Improvement
‣ Human Resource
Development
(Knowledge-
Based Systems)
‣ Processes and
Standard
Operational
Procedures.
Organization &
Management
‣ Risk Assessment
(Risk
Identification Risk
Analysis and
Risk Evaluation
and Prioritization)
‣ Preparation/
Profiling
‣ Targeting
‣ Covering/
Treatment
‣ Evaluation of
outcomes/
Feedback
CRM
Cycle
‣ Key Performance
Area,
‣ Key Performance
Indicators
‣ Performance
Indicators
Monitoring &
Review
‣ Tools, equipment,
and
Infrastructure;
‣ LE IT System;
‣ CRM Module
Embed in CDPS /
Integrated CRM
System;
‣ Data Warehouse,
Business
Intelligence, and
Data Mining.
Technology/
Infrastructure
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2. Benchmark Criteria of the Study
9
Data
Collection
3 different collection methods: interviews,
survey and desk research. OIC MS returned
the limited number of surveys (12 in total)
collection of information for the three case
studies (Turkey, Senegal and Albania CAs).
relies on single criteria - Risk Management
Cycle, on which information can be obtained
for all OIC MS even in the absence of a
survey
1
2
3
Desk Research
and Interviews
Cross-country
Comparison
Assessment method – Cross-country comparison: single criteria
2. Benchmark Criteria of the Study
Objectives and Methodology of the Study 1
Benchmark Criteria of the Study 2
Main Findings – Analysis Results 3
OIC Case Studies 5
OIC MS CRM Challenges / Policy Options 6
Non-OIC Case Studies 4
10
CRM Level of
Implementation
Coverage of the CRM
Process
‣ No CRM
‣ Basic CRM
‣ Medium CRM performances
‣ Advance CRM performances
‣ Full CRM performances
‣ No Coverage
‣ 2 Processes of the CRM
‣ 3 - 4 processes of the CRM
‣ 5 processes of the CRM
‣ All CRM processes covered11
Level of coverage of the CRM cycle
3. Main Findings – Analysis Results
30% Full CRM7% Advance CRM
44% Medium CRM
3% Basic CRM16% No CRM
12
Level of coverage of the CRM cycle in OIC MS3. Main Findings – Analysis Results
13
Level of coverage of the CRM cycle between the three OIC regional groupings
3. Main Findings – Analysis Results
• 34 OIC MS was participating to the
2017 Second Global Survey on
Trade Facilitation and Paperless
Trade Implementation
• 13 (38.24%) reported that they
have fully implemented CRM; 15
(41.42%) reported partial
implementation stage; 2 (5.88%)
in the planning stage and 7 OIC
MS have not implemented CRM14
Level of coverage of the CRM cycle in the OIC MS
3. Main Findings – Analysis Results
2010 ~ 2017
2000 ~ 2010
1990 ~ 1999
16 CDPS
11 CDPS
11 CDPS
Information available for 38 OIC MS
15
Timeline - CDPS Implementation in OIC MS
3. Main Findings – Analysis Results
16
Trade Costs and Time Comparative Analysis between OIC MS,
EU, CEFTA and ASEAN
3. Main Findings – Analysis Results
OIC MS Year of adoption of AEO Concept No. of operators
Albania Adopted legislation
Algeria 2012
Azerbaijan 2013 1
Bahrain Under Development
Bangladesh Under Development Exporter at the pilot stage
Brunei Darussalam Sutera Lane Merchant Scheme 2017
Cameroon Performance Operators’ Contracts 2011 27 Importers
Ivory Coast 2017Experimental phase 2nd quarter
2017 with 10 pilot companies
Egypt 2005 115
Indonesia 2013 9
Iran 2014 11
Jordan Golden List 2005 60
Kazakhstan 2013 5 legal entities
Kyrgyzstan EAEU legislation adopted
Lebanon 2010
Malaysia 2010 59
Morocco 2006 342 (180 category A)
Mozambique 2012 6
Nigeria 2017
Oman 2017
Pakistan Under Development
Saudi Arabia 2017
Senegal Privileged Partnership Programme 2011 22
Sudan Golden List 2016 5
Tajikistan EAEU legislation adopted
Togo Privileged Partnership Framework 2016 10 pilot operators
Tunisia 2010 25
Turkey 2013 225
Uganda 201317 Importers/Exporters
19 Customs clearing agents
United Arab Emirates Golden List programme 2007 26
• 26 out of 57 OIC MS have not implemented AEO;
• 4 MS has the legal framework for authorized traders programme adopted;
• 3 MS are under development;• 24 MS has implemented the AEO or similar
simplification measures concepts.According to the WCO Compendium of AEO Programme (2017):• Total number of the AEO operators in OIC MS
is 606 • In average, 25 operators per MS• Turkey is the leader in the OIC MS with 225
AEO operators, and Morocco with 180 AEO operators (category A).
19
Authorized Economic Operator
3. Main Findings – Analysis Results
Objectives and Methodology of the Study 1
Benchmark Criteria of the Study 2
Main Findings – Analysis Results 3
OIC Case Studies 5
OIC MS CRM Challenges / Policy Options 6
Non-OIC Case Studies 4
20
‣ Customs Strategy provides
valuable input in the LE and
CRM Strategies/Policy;
‣ The laws are fully compliant
with current EU acquis
supported by the other
related regulations and
strategies.
Seneal
‣ The Australian Border Force
(ABF) adopted Strategy
2020 and the Corporate
Plan 2015-19, aligned with
the ABF reform programme;
‣ Main objectives stipulated in
the 2020 Strategy is risk-
based processes of
passengers and goods flow,
customs compliance, and
revenue collection.
Albania
‣ New Legislative framework
(regulatory framework for
CRM, supported by a series
of measures to TF and
ensures compliance)
‣ Strategy related to CRM is
Intelligence-led, risk-based
streamline, simplification of
trade processes, other
border-related risks through
an integrated risk
management approach.21
4.1 Legal, Strategic and Other Mechanism
4. Non-OIC Case Studies
Kosovo Australia New Zealand
‣ Establishment of Risk
Management Commission
(RMC) monitoring the
customs compliance and
revenue collection.
‣ Australian Customs and
Protection of Borders
Service were merged with
the Department of
Immigration and Border
Protection to establish the
Australian Border Force
(2015);
‣ Customs and Border
Protection introduced a
Profile Management Board
and developed a plan for
measurement of the CRM
performances.
‣ Establishment of Customs
Audit and Risk Committee
monitoring the
performances in information
management, enforcement,
revenue collection,
coordinated examination
and delegation of control.
22
4.2 Organization and Management
4. Non-OIC Case Studies
Kosovo Australia New Zealand
‣ Full coverage of the CRM
Cycle
‣ LE IT System for managing
the feedback/irregularities;
‣ Exchange of customs data
in real time with the
neighboring countries
(SEED)/Risk Assessment
on pre-arrival information;
‣ Intelligence based CRM.
‣ Full coverage of the CRM
Cycle
‣ Use of intelligence,
combined with information
flows from other intelligence
agencies;
‣ Common CRM
repository/CRM
management system with
border and OGAs;
‣ National level - exchange of
information
‣ Full coverage of the CRM
Cycle
‣ Automated Targeting
System – assesses pre-
arrival passenger’s
information;
‣ Border Protection Financial
Management Information
System (FMIS)
‣ Exchanges data with OGAs,
National, and International
agencies.
23
4.3 Risk Management Cycle
4. Non-OIC Case Studies
Kosovo Australia New Zealand
‣ The performances of KC
CRM is monitored
continuously -
comparative analysis of
risk indicators/profiles on
the historical data using
BI and data mining.
‣ Evaluation of the
effectiveness of CRM -
Cargo Intervention
Strategy (CIS) and
Differentiated Risk
Response Model
(DRRM).
‣ CRM assessment tool -
Customs Harm Model,
enables NZCS to
measure the impact of
Customs’ enforcement
and risk management
performances.
24
4.4 Monitor and Review
4. Non-OIC Case Studies
Kosovo Australia New Zealand
‣ CRM supported by the
AW, Integrated LE IT
System, DWH/BI and
data mining;
‣ Australian Integrated
Cargo IT System (ICS) -
CDPS with full coverage
of CRM Cycle;
‣ Use of advanced CRM
technique - data mining
and risk profile
simulation.
‣ Joint Border
Management System
(JBMS) - advanced risk
management tools
supporting Customs and
Ministry of Primary
Industry and all border
stakeholders.
25
4.5 Technology
4. Non-OIC Case Studies
Kosovo Australia New Zealand
Objectives and Methodology of the Study 1
Benchmark Criteria of the Study 2
Main Findings – Analysis Results 3
OIC Case Studies 5
OIC MS CRM Challenges / Policy Options 6
Non-OIC Case Studies 4
26
‣ CRM Strategy - Overall
Customs Strategy
‣ Improvement of legal,
technical and
administrative
infrastructure
‣ AEO implemented in
2013, (225 AEO
certificates issued)
‣ LE strategy vs CRM
Strategy (control and
facilitation purposes)
‣ CRM strategic plan
without regulatory
character.
‣ PPP established in 2011.
PPP will transform in
AEO. (11 PPP holders)
‣ Administrative
Instructions,
Implementing
Regulations, and SOP
‣ Implemented the AEO
status (no trader has
applied for AEO)
27
5.1 Legal and Strategic Support to the CRM
5. OIC Case Studies
Turkey Senegal Albania
‣ Decentralized (risk
assessment process
performed on the
local and regional
level)
‣ Centralized (CRM
and Intelligence
Department)
‣ The IT department is
providing continuous
support to the CRM
and the Intelligence
Department.
‣ Centralized (Risk
Analysis, Unit and
the Monitoring Unit)
‣ Plan: Merge CRM
and Intelligence (with
44 customs officers)
28
5.2 Organization and Management
5. OIC Case Studies
Turkey Senegal Albania
‣ Integrated DW
(GUVAS) supports
CRM in identification
of the risks
‣ Cover the full CRM
cycle and is
intelligence-led.
‣ Full automation of
CRM
‣ Inter-Services
Committee
coordinate the CRM
Department
‣ 2 parallel CRM
systems – SIAR and
TAME
‣ The CRM
Department is
responsible for CRM
Cycle
‣ ACA is part of the
SEED project
29
5.3 Risk Management Cycle
5. OIC Case Studies
Turkey Senegal Albania
‣ Monitor performances
related to CRM
‣ Risk Profiles assessment
at every six months.
‣ Quantitative Measurements
‣ National Information and
Documentation System
(FNID - drugs, litigation,
vessels and currency
declarations)
30
5.4 Monitor and Review
5. OIC Case Studies
Turkey Senegal
‣ Advanced IT tools
‣ Integrated customs
data warehouse
(GUVAS) -monitor
and measure
‣ Ongoing project for
implementation of
data mining concept
in TCA.
‣ GAINDE Intégrale
CDPS
‣ SW and TAME for
risk analysis,
targeting and risk
guidance.
31
5.5 Technology
5. OIC Case Studies
Turkey Senegal
Objectives and Methodology of the Study 1
Benchmark Criteria of the Study 2
Main Findings – Analysis Results 3
OIC Case Studies 5
OIC MS CRM Challenges / Policy Options 6
Non-OIC Case Studies 4
32
Policy Options
‣ Revenue collection VS trade facilitation,
community protection, and national
security
‣ Strategic support of CRM with overall customs
strategy and specific Law Enforcement and CRM
Policy
‣ Strategy review and evaluation of
progress. Information to measure progress
regarding non-revenue related strategic
objectives not available
‣ Develop clear goals, objectives and performance
measures (balancing revenue and non-revenue
objectives)
6.1 Legal and Strategic Support to the CRM
6. OIC CRM Challenges / Policy Options
Challenges
33
Policy Options
‣ Action plans are not specific ‣ Development of strong strategic planning process
‣ Legal basis for exchange of security-
related information of high-risk
consignments
‣ Laws: Customs control is based on risk analysis, use of
pre-arrival information and the concept of simplified
procedures
‣ Legal Basis - AEO
‣ Customs and trade partnership programmes for AEO
‣ Customs-to-Business Cooperation to facilitate legal
trade;
6.1 Legal and Strategic Support to the CRM
6. OIC CRM Challenges / Policy Options
Challenges
34
Challenges Policy Options
‣ Lack of or inadequate control
authority
‣ Sufficient authority to undertake inspection functions, with
adequate powers
6.1 Legal and Strategic Support to the CRM
6. OIC CRM Challenges / Policy Options
35
Policy Options
‣ Traditional silo-functional and geographical
lines
‣ Critical “value-added” functions (TF, CRM,
intelligence, PCA)
‣ Lack of change management and continuous
improvement‣ Sound change management strategy
6.2 Organization and Management
6. OIC CRM Challenges / Policy Options
Challenges
36
Policy Options
‣ Cooperation with other border management
agencies
‣ Strong CA HRM Strategic Planning Process
‣ Ensure continuous HR development and career
advancement
‣ Training for customs staff
‣ Development and implementation of a training
programme for customs staff
‣ Conduct organizational competency
assessment/audit to identify current gaps;
6.2 Organization and Management
6. OIC CRM Challenges / Policy Options
Challenges
37
Policy Options
‣ Necessary CRM processes with the requisite
SOPs.
‣ Risk Management Committee
‣ Monitoring process
‣ From partial to full coverage of the CRM cycle
using BPR;
‣ Develop and review CRM processes and integrate
them into the other CA processes
6.2 Organization and Management
6. OIC CRM Challenges / Policy Options
Challenges
38
Policy Options
‣ CRM is not based on compliance
measurement, risk assessment or profiling.
‣ Concept of measurement, object of measurement
and methods of measurement (consequences and
uncertainty)
‣ CRM cycle focus on high-risk goods while
facilitating low-risk shipments‣ Advanced risk assessment techniques and tools
‣ Coverage of CRM cycle based on CRM
functionalities embedded in CDPS
‣ Enhanced use of IT for integration of the full CRM
cycle
6.3 Risk Management Cycle
6. OIC CRM Challenges / Policy Options
Challenges
40
Policy Options
‣ Lack of automated processing
‣ Regular and ad-hoc review and updating of the
risk profiles/indicators
‣ IT systems for management of the
feedback/outcomes from the control
‣ Lack of cooperation/exchange of information
with the relevant stakeholders
‣ Closer contact and communication with traders
and OGAs
‣ Information exchange with other Customs
administrations in real time
6.3 Risk Management Cycle
6. OIC CRM Challenges / Policy Options
Challenges
41
Policy Options
‣ Action plan - elements for measuring the
performances of LE and CRM ‣ Appropriate management information, operational
statistics and performance indicators
‣ Performance information and operational
statistics related to revenue collection
performance
‣ Supportive IT systems
‣ CRM SOP and business processes are poorly
developed ‣ Improving existing business processes
(international standards and procedures)
6.4 Monitor and Review
6. OIC CRM Challenges / Policy Options
Challenges
44
Policy Options
‣ Adequate tools, equipment and infrastructure
for the inspection ‣ Strategic support of CRM focusing on safety and
security instead only on revenue collection;
‣ Pre-arrival/pre-departure information for risk
assessment
‣ IT support for the electronic submission of pre-
arrival/pre-departure information for risk
assessment.
6.5 Technology
6. OIC CRM Challenges / Policy Options
Challenges
45
Policy Options
‣ Manual, non secured management of
information in LE;‣ Integrated Customs Law Enforcement IT System;
‣ CRM Module embedded in CDPS; ‣ Integrated Customs Risk Management System;
‣ Data is frozen in multiple systems/data layers; ‣ Data integration for effective CRM;
‣ Manual data processing and „homegrown“
solutions‣ Data Warehouse / Business intelligence;
6.5 Technology
6. OIC CRM Challenges / Policy Options
Challenges
46
Policy Options
‣ Inconsistent „fact“ base for decisions create
multiple versions of the truth;
‣ Using data mining and predictive analytics‣ Non-application of international standards can
hamper operation of data transfer, and
exchange of messages.
6.5 Technology
6. OIC CRM Challenges / Policy Options
Challenges
47