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By March 14, 2019October 1st, 202640,659 Comments

NVOCC register created and minimum standards set for the

Issuance of NVOCC Bills of Lading

FMC defines NVOCC – Non-Vessel-Operating Common Carrier as:

  • A common carrier that holds itself out to the public to provide ocean transportation, issues its own house bill of lading or equivalent document and does not operate the vessels by which ocean transportation is provided
  • A shipper in its relationship with the vessel-operating common carrier involved in the movement of cargo

As there is no global regulatory body to register, control or regulate NVOCCs around the world, it is difficult to see how many NVOCCs are currently in operation around the world or where they are based..

  • It is widely believed that the US market has the largest number of NVOCC operators in the world.. USA may also be one of the few countries where an NVOCC needs to be registered prior to offering services..
  • NVOCC registration is also required in China as per certain publications which say that the operator must be registered with Ministry of Transportation..
  • Not just in terms of their registration, but there doesn’t seem to be a clear definition on whether the NVOCC operator needs to register their bill of lading or not..
  • Similarly, the requirement or need for registration of an NVOCC in other major jurisdictions is clear as mud..

What is the function of an NVOCC..??

An NVOCC is often termed as a “carrier to shippers” and “shipper to carriers”.. What does this mean..??

At the most basic level, an NVOCC enters into volume-based ocean freight arrangements with the various shipping lines operating across the various trade lanes.. An NVOCC then creates their own tariff based on which they sell space on these liner services to their various clients..

Depending on certain jurisdictions and markets, NVOCC’s activities may include but not restricted to below :
1

Concluding contracts of international carriage of goods with the shippers as carriers;

2

Receiving cargo and delivering cargo as carriers

3

Issuing bills of lading (usually a House Bill of Lading) or other transport documents

4

Collecting freight and other service charges

5

Booking space and arranging shipping with mainline carriers

6

Consolidation and deconsolidation of containers either using own CFS or 3rd party

Ok, now to the subject of this post..

The ICC International Maritime Bureau (IMB) estimates from its work in verifying Bills of Lading that over 95% of all improperly issued Bills of Lading are issued by – yeah you guessed it – Non-Vessel Operating Common Carriers (NVOCCs)..

The IMB identified that there is a prevalence of issuance of incorrect NVOCC bills of lading by the NVOCC which is then presented to banks and other stakeholders in the trading and finance chain, with the aim of defrauding the trade finance system, possibly for the purposes of multiple financing, money laundering, etc..

The IMB has developed a business solution to mitigate the effects of this problem..

The IMB has established a register for Non Vessel Operating Common Carriers (the Register) who agree to abide by the IMB Code of Conduct for the proper issuance of NVOCC Bills of Lading..

The purpose of the Register is to improve anti-fraud standards and provide a mechanism to recognise participating NVOCCs who adhere to a minimum standard of anti-fraud measures in their operations..

Banks who are members of the IMB can now check whether the NVOCC named on the bill of lading presented to them has signed up to the IMB Code of Conduct..

This provides some sort of assurance to the banks and customers that the NVOCC bills of lading issued by these NVOCCs meet acceptable standards.. There are of course consequences for NVOCCs who fail to comply..

TT Club noted that in terms of banking scrutiny, The International Chamber of Commerce’s Commercial Crime Services division has a primary function of protecting the integrity of international trade by seeking out fraud and malpractice and providing reports based on this activity to its members..

Commercial banks conduct thousands of investigations each year in relation to fraudulent bills of lading and these investigations are undertaken by the IMB..

As part of the investigation process, IMB conducts due diligence on all trade documents, including bills of lading, and seeks independent third-party verification to provide an extra level of confidence in transactions..

Safeguard against shipping and freight fraudThis supports banks in relation to their compliance procedures to prevent fraud, money laundering and sanctions breaches, especially since banks are not obligated or have no resources to verify if the goods have been shipped on board..

Suspect bills of lading are those which have false content including the wrong ship, dates, description of cargoes, container numbers or parties..

Perpetrators present such bills of lading to banks to facilitate fraudulent activity including money laundering, fraud, illegal capital flight and to by-pass sanctions..

Shipping and Freight Resource fully supports this initiative of the IMB which sets out the standards for the issuance of NVOCC bills of lading, and also the fact that there will now be a register where NVOCCs can be tracked..

What is your opinion on this initiative..??

This is hugely beneficial to the shipping and freight industry and will surely reduce potential exposures to fraudulent activity throughout the supply chain..

Hopefully, in due course, this will become a regulatory requirement for NVOCCs and maybe even Freight Forwarders, much like a customs broker or clearing agent licence.

PS: As a point of interest, only the ICC and IMB seems to be expanding NVOCC as Non-Vessel Owning Common Carrier whereas everyone else including FMC, World Shipping Council, TT Club seems to expanding NVOCC as Non-Vessel Operating Common Carrier..

Although it could mean both Owning or Operating, would be interesting to hear the rationale.

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40,659 Comments

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  • single_ptOt says:

    OK — have been messing about with this thing for about five months now and it’s basically bookmarked at this point, so figured I’d write something up since someone asked me the other day. Am based in the UK, mostly do football and horses, small stakes, so take it how you like.

    The reason I started using it was actually embarrassing — I couldn’t ever figure out what an each way payout would be with 1/5 odds a place. I’d just wing it and then be surprised. Now type the odds in first, every time, even a simple single bet.

    The single bet calculator is the bit I’m on daily — you put in the price and your stake and it spits out profit and total return instantly, either odds format. Same tool covers the fiddly ones — trebles maths, a lucky 15, yankees, and that’s where I always mess it up. If you fancy a poke about, it lives at kelly criterion excel formula and there’s no login wall, which I appreciated.

    The thing that actually made a difference was the nerdier tools. The implied probability converter that shows what margin’s baked in, plus a kelly staking calculator — I run quarter kelly because full kelly is far too aggressive. Dutching calculator is decent if I’m splitting a race.

    Not all sunshine though. Its interface looks very functional, let’s say — zero frills, which honestly I don’t mind but some will. On my phone it’s usable though the bigger tables are a squeeze. There’s nothing on the app store, it’s a website and that’s it — doesn’t bother me just flagging it.

    Right, that’s me. Free, not plastered in adverts, works. Anyone who even now works out returns on a calculator app, give it a go — saves me a load of dumb bets I’d have regretted.

  • single_bzpr says:

    So — been on this thing for maybe a few months now and it’s stuck on my phone, so thought I’d say something since a mate asked me the other day. Am in the UK, generally do football and horses, a fiver here and there, for context.

    The reason I started using it was honestly pretty stupid — I never could figure out what an ew return actually was when the place terms changed. Basically I’d wing it and get a shock. Now I type the odds in before every slip, even a simple single bet.

    Their single bet calculator is the part I’m on daily — you drop in stake and odds and it shows profit and total return straight away, fractions or decimals. There’s also the fiddly ones — acca and treble maths, lucky 15 and lucky 63, yankees, and that’s where I’d always lose track. Have a go yourself, it’s over at betting probability and there’s no login wall, which I appreciated.

    One thing that genuinely shifted things for me were the geekier extras. The probability thing that shows what margin’s baked in, plus a kelly staking tool — I use half kelly since full stakes are a quick route to a dead bankroll. The dutch tool is decent when I’m splitting a race.

    It’s not perfect mind. Its interface is pretty plain — zero frills, it’s clearly function over form. On my phone it’s fine although the bigger tables make you pinch and zoom. And no proper app, it’s a website and that’s it — fine by me but you asked.

    Right, that’s me. Free, barely any ads, does the job. If you still works out returns on a calculator app, give it a go — it’s saved me plenty of “wait, that’s it?” moments.

  • single_mySn says:

    So — have been messing about with this thing for maybe four months now and it’s basically bookmarked at this point, reckon I’d chuck my thoughts in since someone asked me a few days back. Am in the UK, generally bet football and racing, small stakes, for context.

    How I found it was actually embarrassing — I couldn’t ever get my head round what an each way payout would be once you get five places instead of three. I’d just wing it and moan when the payout landed. Now type the odds in before every slip, even a straight one-selection punt.

    The single bet calculator is the one I’m on daily — you put in your stake, the odds and it spits out returns straight away, either odds format. There’s also the fiddly ones — doubles and trebles returns, lucky 15 and lucky 63, a yankee, honestly that’s where most people I know got it wrong. If you fancy a poke about, it’s over at super heinz bet example and it’s free with no account nonsense.

    One thing that genuinely made a difference is the nerdier tools. There’s an implied probability calculator which shows you what margin’s baked in, and a kelly criterion tool — I run quarter kelly because full kelly is terrifying. Dutching calculator is handy too for when I’m spreading across selections.

    Couple of gripes. The design looks very functional, let’s say — not much flash, looks like it was built by someone who cares more about maths than colours. Phone-wise it works although the bigger tables need a bit of scrolling. Also there’s no app, it’s browser only — fine by me just flagging it.

    Anyway. Costs nowt, no ads shoved in your face, does the job. If anyone still adds it up in their head, have a look — it’s saved me plenty of dumb bets I’d have regretted.

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