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2016 OAS Guidelines

3.III.3.2. Postal operators

A postal operator has its own specific characteristics, and it is necessary to take into account its characteristics and the risks associated with its activity. As expected, the proven solvency criterion will be assessed in the same way as for other operators, so below we will focus on certain specific issues related to the other criteria for obtaining AEO status.

Compliance with customs requirements

A postal operator provides delivery and dispatch services to a large number of small customers and users whose reliability is not easy to monitor. As a result, issues related to customs duties, as well as security and safety guarantees, may arise. Among the various examples of risk areas associated with customs operations, the following are worth mentioning:

  • the high number of "small" shipments, i.e. those of low weight or value;
  • the unreliability of customer statements (mostly individual): Errors and omissions in declarations regarding the value and incorrect description of the quality of the contents of the shipments, absence or inadequacy of the reference documents accompanying customs declarations and, as a result, difficulties in complying with customs requirements (lack of certifications, licenses, etc.);
  • delivery delays caused by the carrier;
  • high risk of “lost” (misplaced) shipments.

Therefore, during the customs compliance audit process, in addition to taking into account the size and type of economic operator, the auditor will also consider the number of violations compared to the total number of transactions submitted annually to assess potential risks. The management of the registration process in the declarant register, with the exemption from the obligation to present the goods, and the customs warehousing regime are the most important elements that must be assessed on a case-by-case basis, along with the remaining risks.

Accounting and logistics systems

One of the risks to consider is inventory management and reporting of undelivered mail and packages (when the recipient has not been located or picked up). Regarding this essential aspect, it is necessary to assess the storage costs (and, where applicable, subsequent destruction, when specified in the regulations) or the costs associated with returning the goods to the sender. This issue can have a significant impact on the traceability of customs and accounting operations and impact logistics organization, as well as management, costs, inventory protection, and warehouse security.

Such an operational situation requires the possibility of having an IT system equipped with sufficient security and structured in a way that guarantees the audit trail of all customs operations, both export and import, as well as the protection of the data contained therein.

When assessing the effectiveness of the internal control system, it is important to check, in addition to the segregation of duties, whether there are individuals responsible for ensuring compliance with the rules relating to customs procedures, as well as how the associated risks are identified and addressed in practice. Consequently, the impact of various potential negative events on the operator's activity must be assessed, and the effectiveness of the procedures applied to take corrective action in cases of non-compliance must be carefully examined.

On the other hand, also in relation to internal control, it is important to check which databases and information procedures are used to store customer and shipping data.

Another aspect that needs to be evaluated is the management of ground transportation, especially if it involves an airport operator. In this case, it will be necessary to evaluate the reliability of the drivers responsible for collecting the packages.

Safety requirements

In this context, hiring personnel should be carefully considered. It is important to consider the number of temporary workers and the frequency with which they are hired. The higher the number and frequency, the higher the potential risk of infiltration for the purpose of carrying out illicit activities, such as the introduction of package bombs, drugs, etc.

Therefore, the selection criteria adopted for hiring personnel to be assigned to special operations, such as those in direct contact with sensitive goods in storage locations or high-risk areas, will need to be carefully evaluated.

It will also be necessary to check the frequency with which the operator monitors staff, in accordance with legislation. Contracts with employees should also be carefully examined.

All personnel, regardless of the type of employment contract, must be guaranteed adequate professional training, particularly regarding customs regulations and procedures. To ensure high quality in the application of security and protection procedures, adequate training is required, including for personnel responsible for scanning certain goods awaiting shipment.

To ensure the security of the international supply chain, a postal operator must:

  • Develop safety and security guidelines to inform and train staff on the risks associated with postal operations;
  • have an adequate internal organization that allows for increasing the frequency of inspections on the occasion of certain risk events or following the publication of certain intelligence reports;
  • Properly train postal inspectors assigned to security checkpoints and provide them with up-to-date information on how to identify potentially dangerous shipments, taking into account risk indicators such as:
    • failure to indicate the sender;
    • "sensitive" recipients (diplomats, political institutions, financial bodies, religious communities, media, etc.);
    • the presence of marks or stickers intended to avoid controls, such as: "do not expose to x-rays", "confidential", "no postal inspection required", "do not open", etc.;
    • unusual macroscopic physical or chemical characteristics (e.g. e.g., hot packages, presence of unusual odors, loss or spillage of contents, discoloration of packages, grease stains, noises coming from inside, etc.).

Furthermore, the postal operator must adopt measures relating to the logistical and organizational dimensions of the spaces used for the storage of items, such as the following:

  • have special areas where security checks can be carried out on incoming and outgoing shipments;
  • Physically separate goods subject to control from those still pending inspection;
  • require customers to use products whose traceability can be guaranteed;
  • formulate a reaction plan to detect, isolate and neutralize the detected threats;
  • Create a security contact office for customs, police, intelligence, and health authorities, taking into account the type of service provided and its importance.

In conclusion, given the significant size and special characteristics of the service offered by postal operators, as well as the number of transactions, and in order to establish reliable procedures in the areas of customs, logistics, accounting, and security, it is essential that all procedures be rigorously standardized, with detailed internal procedural protocols that are put into effective routine practice.