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Summary: The US Government Accountability Office (GAO) is an independent government watchdog organization that has been publishing many reports on the US government’s supply chain security initiatives over the past ten years. This article reviews 25 most relevant GAO’s reports that discuss strengths, weaknesses and future challenges of the US policies and regulations on supply chain security. The review findings reveal interesting facts about similarities and differences of the US and the EU approaches to supply chain security. This comparison opens new venues for further Transatlantic benchmarking as well as harmonisation and mutual recognition of supply chain security programs. This review was conducted as part of European FP7-Project CORE. The reviewed document is available for download here: https://hicl.org. Review by Toni Männistö (CBRA)
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Full review: The GAO reports suggest that the US administration has been struggling with effective performance monitoring and auditing of its supply chain security initiatives. The reports indicate that there is some confusion about costs of security initiatives for the government and for the business community. There is also a lack of common understanding about the actual benefits of many of these programs. The GAO reports also urge US government officials to adopt risk-based approach to supply chain security, for example to use information and intelligence to assess risk levels of specific shipments, people, trading companies, and other entities, and then employ security solutions that are commensurate to the risk level. The GAO reports also emphasize the importance of involving the industry in the process of defining new policies and regulations.
Altogether, the review team found that the GAO documents are not only highly relevant for SCS management and governance but also of high quality. The study concludes that it might be useful for the EU to establish a quality-assurance organization similar to the US GAO. This new EU body would oversee spending of the EU and its member states on supply chain security programs and projects and this way improve efficiency of such investments.
Reference: Männistö, T., and Hintsa J., (2015), “A Decade of GAO’s Supply Chain Security Oversight,” Proceedings of the Hamburg International Conference in Logistics (HICL), September 24-25, 2015, Hamburg
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Summary: In a recent study, a joint CBRA-INTERPOL research team investigates what kind of training material would help law enforcement agencies to fight crime in the context of global supply chains. The team conducted a pilot survey at the LE TrainNet Meeting (Networking Meeting of the Law Enforcement training institutions) which took place in Baku, Azerbaijan, 28- 29 April 2015. Findings of the pilot survey will be used to launch a large EU-wide survey on law enforcement agencies’ training needs regarding supply chain security. The survey findings also guide production of new training and educational material that the FP7 CORE is currently producing. The reviewed document is available for download here: https://hicl.org. Review by Toni Männistö (CBRA)
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Full review: The article concludes that law enforcement agencies generally recognise supply chain security training as a worthwhile investment for their organisations. In partuclar, the law enforcement agencies call for new supply chain related training material especially regarding narcotics and drug precursor trafficking, corruption financial crimes and tax evasion, trafficking in human beings, trafficking in counterfeit goods, terrorism and cybercrime. They advocate increasing use of modern training techniques and tools, such as e-learning, case-based teaching, and role-playing exercises.
Other findings show that law enforcement agencies consider it very useful to develop new training and educational material that would help them to enable and encourage multi-agency collaboration, for example data sharing between police agencies and customs. The survey respondents also expressed their interest in new training material that would focus on human factors of transnational crime (e.g., motives and underlying social dynamics) and intelligence-led policing.
It is important to notice that only 16 people responded to the Baku pilot survey. The response rate was 23.2%, given there were 69 delegates registered for the LEA TrainNet meeting. The relatively low number of respondents and the relatively low response rate indicate that there is a definite need for a larger EU-wide follow-up survey.
Reference: Hintsa, J., Ahokas, J., Gallagher, R., and Männistö, T., (2015), ”Supply Chain Security: Survey on Law Enforcement Agencies’ Training Needs”, Proceedings of the Hamburg International Conference of Logistics (HICL), September 24-25, 2015, Hamburg.
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Summary: Thailand is interested in coordinated border management conceptualization and implementation like many other countries. There are, however, some special challenges that Thailand faces when the country tries to strengthen cooperation with its neighbouring countries. The reviewed document is available for download at: Collaborative Border Management in Thailand and Neighboring Countries: Needs, Challenges and Issues.
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Full review: The report proposes a set of recommendations for implementing coordinated border management:
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Summary: The Inter-American Development Bank (IDB) reports that more than 95% of commercial goods in the Mesoamerican region are transported overland using the Pacific Corridor. This traffic represents approximately 6 billion USD worth of goods on a highway which runs from Puebla, Mexico to Panama and crosses six national borders. The problem with the Pacific Corridor is with unreliable, inefficient and substandard infrastructure. In 2008, to upgrade the inadequate infrastructure, the IDB launched a ambitious project called International Goods in Transit. According to the report, the results of the project were outstanding: average time to cross a border was reduced from 62 minutes to eight. The project also succeeded to reduce the number of documents that traders needed to submit to border control agencies. The two reviewed files are available for download at: Interoperability at the Border: Coordinated Border Management Best Practices & Case Studies and Automating the Control of Goods in International Transit: Implementing the TIM in Central America.
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Full review: The solution, that the International Goods in Transit project produced, is basically an electronic system for managing and controlling the movement of goods in transit. The system builds on three main pillars that unlock better services at border crossing:
Important lessons learned from the project include the following:
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Summary: An Integrated Border Management (IBM) Strategy was written in Croatia in accordance with the guidelines of the European Union and in collaboration with international experts. This strategy and its implementation action plan was adopted by the Croatian government on the 21 April 2005. The reviewed document is available for download at: Strategy for Integrated Border Management (Croatia).
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Full review: The main objective of the Integrated Border Management (IBM) Strategy is to provide effective support for economic development of the country and to raise the standard of living of citizens. The strategy also seeks to protect life and health of people and their property from cross-border crime. Integrated Border Management requires participation of many government agencies, including border police, customs, border veterinary service, border phytosanitary service, border sanitary service and the state inspectorate. Many times also state authorities in charge of culture, mining and radiation protection contribute to the IBM Strategy formulation and implementation.
As part of the Strategy, the Croatian government created a new interdepartmental working group. The primary objective was to facilitate cross-border traffic through reduction overlapping border control activities. The working group eliminated duplicate processes by aligning responsibilities of border control agencies and by exploiting the time of the relevant synergies between relevant governmental bodies. The working group launched initiatives in following areas:
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Summary: The Canada Border Services Agency (CBSA) has a dual mandate (1) to facilitate cross-border movements of cargo and people and (2) to protect security and safety of the Canadian people. The agency seeks to provide integrated border services, by closely cooperating with other Canadian border control agencies as well as with foreign customs administrations. The reviewed document is available for download here: Customs Cooperation Case Study for Canada.
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Full review: Forms of cooperation depend on needs of the partner agencies, but the cooperation typically includes:
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Summary: This document contains two annexes. Annex 1 covers the Customs 2020 Work Programme for 2015. It describes the activities and the budget breakdown for the year 2015 for pursuing the objectives laid down in Regulation 1294/2013 that establishes an action programme for customs in the European Union between 2014 and 2020. Annex 2 covers Fiscalis 2020 Work Programme for 2015. It covers the action plans and the budget breakdown for 2015 in relation to Regulation 1286/2013 establishing an action programme to improve the operation of taxation systems in the European Union for the period 2014-2020. The activities and financial coverage are based on three main items-action grants, procurement and other actions. The document is available for download at: http://ec.europa.eu/taxation_customs/resources/documents/taxation/tax_cooperation/fiscalis_programme/legal_texts_docs/awp_2015_en.pdf (accessed on 12.3.2016)
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Full review: The overall objective of the Customs 2020 programme is to facilitate the functioning and modernisation of the customs union in order to strengthen the internal market by means of cooperation between participating countries, their customs authorities and their officials. It is designed to support the shaping and implementation of the UCC (Union Customs Code).
The overarching objective of Fiscalis 2020 programme is to support the fight against tax fraud, tax evasion and aggressive tax planning and the implementation of Union law in the field of taxation. The Fiscalis 2020 programme is a tool, which supports and implements the overall tax policy at the European Union level.
In the Customs 2020 programme, action grants cover grants for joint actions, grant for expert team on new Import Control System (ICS) and grant for expert team on Automated Export System / New Computerised Transit System (AES/NCTS). The Joint Actions grants will fund activities related to the implementation of Union law and policy in the field of customs; improving the European Information Systems for customs, the adoption of best working practices, enhancing the expertise of customs officials, and improving cooperation between relevant organizations both on the EU and international levels. The grant for the expert teams on ICS and AES/NCTS will help achieve the objectives of the year. These objectives include the implementation of the UCC and the required Customs Information Systems in particular, and imposing a tight schedule in terms of IT systems implementation until 2020.
Under Fiscalis 2020 programme, the action grants only cover joint actions that will fund activities related to improving the European Information Systems for taxation, the administrative cooperation, the competence of tax officials, the implementation of Union law in the field of taxation, and for streamlining administrative procedures.
Procurement activities for both the programmes cover IT Capacity Building Actions and Joint and Competency Building Actions. The contracts for public procurement related to IT Capacity building concern the development, maintenance, operation, and quality control of Union components of the existing and new European Information Systems. Procurement activities related to Customs 2020 aim at interconnecting customs authorities, whereas as those associated with Fiscalis 2020 aim at interconnecting taxation administrations. The Joint and Competency Building procurement contracts concern the development, maintenance, support and dissemination of common customs (for Customs 2020) or taxation training (Fiscalis 2020); online collaboration services; staff performance building services; scientific studies, and communication support.
Other expenditures include the funding of external experts who may be invited to contribute to selected activities for achieving the overarching objectives of the two programmes.
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Summary: The Committee of Sponsoring Organizations of the Treadway Commission, COSO, defines Enterprise Risk Management, ERM, as a process, effected by an entity’s board of directors, management and other personnel, applied in strategy setting and across the enterprise, designed to identify potential events that may affect the entity, and manage risk to be within its risk appetite, to provide reasonable assurance regarding the achievement of entity objectives. The entity objectives are set forth in following four categories: (i) Strategic – high-level goals, aligned with and supporting its mission; (ii) Operations – effective and efficient use of its resources; (iii) Reporting – reliability of reporting; and (iv) Compliance – compliance with applicable laws and regulations. According to COSO, ERM enables management to effectively deal with uncertainty and associated risk and opportunity, enhancing the capacity to build value. Within the context of FP7-CORE project – and, supply chain security management in general – ERM can be seen as a useful approach particularly when it comes to aligning security risk appetite and strategy; to enhancing security risk response decisions; and to reducing security related operational surprises and losses. Some other ERM aspects such as seizing opportunities (“positive risks”) may not apply in supply chain security management context. One more interesting note, which could also be applied for supply chain security: everyone in an entity has some responsibility for ERM. This executive summary document is available for download at: http://www.coso.org/documents/coso_erm_executivesummary.pdf
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Full review:
Background: The first version of the “Internal Control – Integrated Framework” was issued by the Committee of Sponsoring Organizations of the Treadway Commission, COSO, in early 1990s, to help businesses and other entities assess and enhance their internal control systems. The change of the millennium saw heightened concern and focus on risk management, and it became clear that a need exists for a robust framework to effectively identify, assess, and manage risk. In 2001, COSO initiated a project, and engaged PricewaterhouseCoopers, to develop a framework that would be readily usable by managements to evaluate and improve their organizations’ enterprise risk management.
According to COSO (p.1), Enterprise Risk Management, ERM, encompasses:
• Aligning risk appetite and strategy – Management considers the entity’s risk appetite in evaluating strategic alternatives, setting related objectives, and developing mechanisms to manage related risks.
• Enhancing risk response decisions –Enterprise risk management provides the rigor to identify and select among alternative risk responses – risk avoidance, reduction, sharing, and acceptance.
• Reducing operational surprises and losses – Entities gain enhanced capability to identify potential events and establish responses, reducing surprises and associated costs or losses.
• Identifying and managing multiple and cross-enterprise risks – Every enterprise faces a myriad of risks affecting different parts of the organization, and enterprise risk management facilitates effective response to the interrelated impacts, and integrated responses to multiple risks.
• Seizing opportunities – By considering a full range of potential events, management is positioned to identify and proactively realize opportunities.
• Improving deployment of capital – Obtaining robust risk information allows management to effectively assess overall capital needs and enhance capital allocation.
COSO (pp.3-4) states that ERM consists of eight interrelated components, derived from the way management runs an enterprise and are integrated with the management process:
• Internal Environment – The internal environment encompasses the tone of an organization, and sets the basis for how risk is viewed and addressed by an entity’s people, including risk management philosophy and risk appetite, integrity and ethical values, and the environment in which they operate.
• Objective Setting – Objectives must exist before management can identify potential events affecting their achievement. Enterprise risk management ensures that management has in place a process to set objectives and that the chosen objectives support and align with the entity’s mission and are consistent with its risk appetite.
• Event Identification – Internal and external events affecting achievement of an entity’s objectives must be identified, distinguishing between risks and opportunities. Opportunities are channeled back to management’s strategy or objective-setting processes.
• Risk Assessment – Risks are analyzed, considering likelihood and impact, as a basis for determining how they should be managed. Risks are assessed on an inherent and a residual basis.
• Risk Response – Management selects risk responses – avoiding, accepting, reducing, or sharing risk – developing a set of actions to align risks with the entity’s risk tolerances and risk appetite.
• Control Activities – Policies and procedures are established and implemented to help ensure the risk responses are effectively carried out.
• Information and Communication – Relevant information is identified, captured, and communicated in a form and timeframe that enable people to carry out their responsibilities. Effective communication also occurs in a broader sense, flowing down, across, and up the entity.
• Monitoring – The entirety of enterprise risk management is monitored and modifications made as necessary. Monitoring is accomplished through ongoing management activities, separate evaluations, or both.
Lastly, as potential readers / users of this report, COSO suggests following: Board of Directors; Senior Management; Managers and other personnel; Regulators; Professional Organizations; and Educators.
CORE1106
https://www.dropbox.com/s/aetbp8jr6dr4z31/CORE1106-coso_erm_executivesummary.pdf?dl=0
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Summary: This guidebook outlines the key elements and benefits of the Customs-Trade Partnership Against Terrorism (C-TPAT) program that is designed to secure global supply chains and to improve United States border security. Document is available at: https://www.cbp.gov/sites/default/files/documents/C-TPAT%20Program%20Benefits%20Guide.pdf (link tested on 3 March 2016)
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Full review: C-TPAT partners receive a wide range of benefits listed below:
In addition, some benefits are associated with Mutual Recognition Arrangements (MRAs) when two customs authorities formally acknowledge the security requirements or standards of one program, as being equivalent to the other program. Some of the resulting benefits to the trade community are illustrated below:
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Summary: This addendum document lists cargo security best practices with focus on prevention of weapons of mass effect, terrorists, and/or contraband from infiltrating into the international supply chain. Each best practice is linked to a specific business entity, such as a Manufacturing Company, a Highway Carrier, an Importer or a Foreign Consolidator but these may apply to other business types as well. The document is available at: https://www.cbp.gov/sites/default/files/documents/ctpat_bpa_2009_0.pdf (link tested on 3 March 2016)
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Full review: The best practices are outlined as follows:
Risk assessment: Programs are in place to enable the identification of the most vulnerable supply chain areas, to grade suppliers supply chain security criteria. Specific processes have been developed to manage the supplier’s products, software and services and internal monitoring systems to enhance the safety and security procedures.
Business partner requirements: Several security measures have been taken by entities. These include conducting supply chain security audits to ensure compliance of non-C-TPAT business partners; carrying out security audits of a foreign manufacturer; making security self-assessments, conducting onsite inspections to ensure freight security; shipping cargo only through accredited ports and steamship lines; monitoring compliance of manufacturing facilities; screening procurements to identify ineligible status of suppliers, and performing audits of business partners.
Conveyance/Container/Trailer Security: Examples of such security practices are: integrating special security features in the GPS (global positioning system); using laser beams to protect trailers; using colour codes for matching consignments; installing infrared sensors in docks to prevent unauthorized access; using special codes to identify correct shipments; documenting all seal changes for shipments in transit; ensuring delivery by authorized Company drivers; sealing containers; operating through C-TPAT carriers; using only “seaworthy” containers; installing in-transit temperature data sensors to ensure product quality; enclosing container storage area; conducting non-intrusive inspection prior to loading a vessel; establishing specific inspection points; using multiple security devices on each container; using automated container yards; instructing foreign suppliers to provide inspection checklists; using dock locking arms for container storage; installing motion sensors in a trailer; operating through contracted highway carriers and security services; documenting a seal destruction policy, and so forth.
Physical Access Controls: Some practices by Importers include establishing multiple security stations within the building; using metal detectors for employees; installing an electronic swipe card/ lock box systems for access control for sensitive documents; conducting electronic scanning of visitors’ drivers licenses; utilizing a third-party software system to manage key inventory; and providing panic buttons for company employees.
Physical Security: Several innovative solutions have been designed to ensure physical security, such as electronically closing gates and activating tire puncturing devices to prevent vehicle exits; using an electronic security information reporting system, installing invisible electronic fences; installing laser sensors; setting up optical light beams to detect intruders; fitting double locks on doors; Installing infrared sensors on fences; using body alarm functions for emergencies; appointing patrolling guards, using multiple glass meeting rooms; using multiple interior infrared security alarm beams to detect unauthorized access; and installing security guard view towers.
Personnel Security: An Importer requires business partners to provide a monthly master list of employees and immediately notify when their employees are hired or terminated, in order to ensure that only authorized business partner’s employees enter the manufacturing facilities.
Security Training/Threat Awareness/Outreach: Business entities have invested in a wide range of training programs. One such initiative is the four-tier C-TPAT training targeted for management and supervisors, shipping and receiving personnel, internal personnel dealing with contractors and hourly staff. Other businesses use different approaches, like establishing an online training portal;; offering general security training and of site-specific training for security guards; issuing security advisories; making regular security awareness assessments; establishing a situation matrix chart to address possible incidents; establishing a direct communication channel between the president of the company and employees; putting in place a toll free hotline for company personnel; conducting security drills and exercises; establishing a web-based security awareness training; documenting security incidents in a central database; and establishing a global communication system to contact all employees and contractors remotely.
Procedural Security: Instances of this type of security measures include a bio-thermal intrusion alarm system; a global SAP network to generate all written orders for import and export; automatic screening procedures of purchase orders for restricted parties; lock boxes for sensitive documentation; an automated loading module called the Automatic Truck Loading System (ATLS); a container seal number as the shipment tracking (invoice/bill of lading) number, and so forth.
Information Technology (IT) Security: Such security practices include a biometric fingerprint door lock; a remote data backup center; a retina scanning system for access to the computer system; requiring supervisory approval to copy data; use of electronic password protected purchase orders; establishing a daily “e-test” for employees to access computers, and so forth.
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