A recent alert issued by the UK's National Crime Agency (NCA) warns that as furloughed staff in the port and airport sectors return to work, they could be targeted by organised criminal groups (OCGs) seeking to exploit their knowledge of their company's controls and processes.
The alert, aimed at companies including port and airport operators, contractors, couriers and freight operators, points out that OCGs "frequently offer financial support in return for knowledge and access to restricted areas. This can be used to help smuggle illicit commodities such as firearms and drugs, or the movement of vulnerable people and children through organised immigration crime".
Globally, in the last few months, there have been a number of related high profile allegations published by international news outlets suggesting that the NCA's infiltration warning isn't restricted to the UK - for example, the alleged infiltration by drug traffickers of a major airline in Australia and the recent arrest of several airline staff in India in relation to gold smuggling allegations.
As previously discussed in an earlier Clyde & Co article examining corruption in the shipping and ports sectors, at a local level individual companies should be doing all they can to control corruption within their own organisations, reduce their exposure to enforcement action and make the job of drug traffickers and other criminals more difficult.
As staff return to work, it would be a sensible measure to revisit and refresh revisit anti-bribery and corruption controls and reinforce employee codes of conduct. It is also worth recognising that personal financial pressures, which are likely to have been experienced by many employees who have been laid off or furloughed, can be a significant red flag - preventative and detective controls and processes should reflect that.
Some measures that can help include:
- Employee screening processes - consider rescreening returning employees in higher risk roles
- Continual reinforcement of anti-bribery and corruption policies and procedure requirements through training and awareness initiatives,
- Refresher training on confidential whistleblowing hotlines, including reminders on how and when to make a report,
- Implementation of support mechanisms and guidance for staff who are subject to corrupt approaches or who are experiencing financial difficulties,
- Enhanced monitoring and testing of internal controls and staff compliance,
- Robust due diligence on third party service providers and suppliers, and
- A Board led focus on the importance of transparency and ethics amongst all employees.
If you would like some help to revisit or refresh your controls in this area, or check if they are working effectively, please contact Neal Ysart, Lead Regulatory & Investigations Advisor at firstname.lastname@example.org / Tel: +971 55 138 9250 or your usual Clyde & Co point of contact.
As global restrictions on the movement of people and goods are further relaxed, the alert warns that staff who have a detailed knowledge of controls and processes around the border could be targeted.