TT Talk – The IMB NVOCC Register
Reducing bills of lading risks
While there may be valid trading reasons that give rise to bill of lading difficulties, there is an unhealthy under-belly of criminal activity.
TT Talk canvassed some trading issues relating to bills of lading in the December 2018 edition. Reference within those articles was made to the English law position articulated in Motis Exports case1, explaining the risk exposure to bill of lading issuers and stakeholders relying on the documentation. This article applies to the industry vulnerability to fraudulent activity.
Banking scrutiny
The International Chamber of Commerce’s Commercial Crime Services division has a primary function of protect the integrity of international trade by seeking out fraud and malpractice and providing reports based on this activitiy to its members.
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Commercial banks commence thousands of investigations each year in relation to fraudulent bills of lading which are undertaken by the International Maritime Bureau (IMB), a division of CCS. Through 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. This supports banks in relation to their compliance procedures to prevent fraud, money laundering and sanctions breaches.
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.
It is recognised that NVOCCs and freight forwarders play a vital role in international trade and whilst the majority operate to extremely high standards, there are inevitably those who for a variety of reasons may deliberately or recklessly issue bills of lading with false content. It is important that safeguards are in place to ensure the security of bills of lading and that there are systems in place to track any misuse.
As a result of recent trends involving bill of lading fraud and a growing concern of their stakeholders, the IMB developed a new initiative, unveiled at Enterprise, Singapore on 15 January 2019, during a panel discussion on the manipulation of bills of lading attended by over 100 delegates from banks, logistics companies and lawyers. The primary objective is to provide a common open platform from which to improve anti-fraud standards and to give due recognition to participating NVOCCs who adhere to the minimum standards established within the platform.
NVOCC vulnerability
"IMB estimates that over 95% of all improperly issued bills of lading are issued by NVOCCs."
From this work, IMB estimates that over 95% of all improperly issued bills of lading are issued by NVOCCs. This is a staggering finding, albeit relating to a small percentage of the total transactions, but a clear indicator of the vulnerability of some elements of the NVOCC sector.
Announcing IMB NVOCC register
“Maintaining the integrity of the bill of lading is of paramount importance to all stakeholders in global trade”
TT Club believes that this initiative to improve standards and reduce potential exposures to fraudulent activity through the supply chain is beneficial to the industry and would therefore encourage its NVOCC membership to evaluate the platform and consider participation in it.
We gratefully acknowledge the assistance in the preparation of this article of Pottengal Mukundan, Director, International Maritime Bureau, ICC-Commercial Crime Services
The initiative introduces an open source NVOCC register in conjunction with a new IMB Code of Conduct which all participating NVOCCs are required to adopt. The Code of Conduct is supported by an online training course which sets out minimum standards for the issuance of NVOCC bills of lading. Participating NVOCCs remain accountable where a document they have issued is found to be fraudulent, however it is anticipated that a wider knowledge of good practice will result in fewer cases of fraud being identified.
Maintaining the integrity of the bill of lading is of paramount importance to all stakeholders in global trade. Where fraudulent activity is allowed to continue, there is a real danger that key stakeholders de-value the worth of the bill of lading. Inevitably, should the industry not be able to address commercially the challenge presented by the use of fraudulent documents, there is a risk that regulations may be required. This initiative recognises and seeks to address this industry wide challenge, seeking to promote awareness and support compliance with acceptable trade practices.
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So — have been messing about with this thing for about five months now and I keep coming back, so figured I’d write something up since a mate asked me a few days back. Am based in the UK, mainly do football and horses, nothing mad, just so you know where I’m coming from.
How I found it was actually a bit daft — I could never work out what an each way return would be once you get five places instead of three. I used to just guess and then be surprised. These days I stick my stake in first, every time, even the boring singles.
The single bet calculator is the one I open most — you drop in stake and odds and it shows profit and total return instantly, fractional or decimal, doesn’t matter. Same tool covers the fiddly ones — acca and treble returns, lucky 15s, a yankee, which is where I’d always got it wrong. If you want a look, it’s here betting super heinz and it’s free with no account nonsense.
The thing that genuinely made a difference was the nerdier tools. They’ve got an implied probability converter and it makes obvious how much the bookie’s taking, plus a kelly criterion calculator — I use half kelly since full stakes are a quick route to a dead bankroll. The dutch tool is handy too if I’m covering two or three runners.
It’s not perfect mind. Its interface is pretty plain — zero flash, looks like it was built by someone who cares more about maths than colours. Phone-wise it’s usable although the bigger tables are a squeeze. And no proper app, it’s a website and that’s it — fine by me but you asked.
Right, that’s me. Costs nowt, no ads shoved in your face, does what it says. Anyone who honestly works out returns on a calculator app, try it — it’s saved me a load of arguments with the bookie.
Right — been using this thing for maybe five months now and it’s basically bookmarked at this point, reckon I’d chuck my thoughts in since a mate asked me a few days back. I’m UK based, mostly bet football and racing, small stakes, just so you know where I’m coming from.
The reason I started using it was honestly pretty stupid — I couldn’t ever figure out what an e/w return actually was once you get five places instead of three. Basically I’d guess and then be surprised. These days I type the odds in first, every time, even a straight one-selection punt.
Their single bet calculator tool is the one I open most — you drop in your stake, the odds and it shows returns instantly, fractions or decimals. It also handles the multiples — doubles and trebles maths, lucky 15s, yankees, honestly that’s where I always mess it up. If you fancy a poke about, it lives at bet calculator lucky 63 and it’s free with no account nonsense.
One thing that genuinely made a difference is the more serious bits. The probability converter which shows you the overround, and a kelly criterion tool — I use half kelly because full kelly is far too aggressive. The dutching one gets used a fair bit when I’m covering two or three runners.
It’s not perfect mind. The layout feels a bit basic — not much frills, it’s clearly function over form. On my phone it’s fine although the bigger tables make you pinch and zoom. And no app, just the site — slight shame but worth saying.
Right, that’s me. Doesn’t cost anything, no ads shoved in your face, does the job. If anyone still works out returns on a calculator app, give it a go — it’s saved me plenty of “wait, that’s it?” moments.
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Right — been using this thing for about four months now and it’s stuck on my phone, so figured I’d chuck my thoughts in since a lad on another thread asked me the other day. I’m based in the UK, mainly stick to footie and the horses, a fiver here and there, just so you know where I’m coming from.
What got me on it was genuinely pretty stupid — I could never work out what an each way return actually was with 1/5 odds a place. Basically I’d eyeball it and then be surprised. These days I type the odds in first, every time, even a straight one-selection punt.
Their single bet calculator tool is the bit I open most — you drop in the price and your stake and it shows profit and total return straight away, fractional or decimal, doesn’t matter. There’s also the bigger stuff — acca and treble returns, lucky 15s, a yankee, and that’s where I’d always got it wrong. If you want a look, it’s over at vig calculator decimal and there’s no login wall, which I appreciated.
The thing that really changed how I bet is the more serious extras. They’ve got an implied probability converter that shows what margin’s baked in, and a kelly tool — I run quarter kelly since full stakes are a quick route to a dead bankroll. Dutching calculator is handy too when I’m covering two or three runners.
Couple of gripes. Its design looks very functional, let’s say — not much polish, it’s clearly function over form. On mobile it’s usable but the lucky 63 breakdown need a bit of scrolling. There’s no app, it’s browser only — doesn’t bother me just flagging it.
Anyway. Costs nowt, no ads shoved in your face, works. Anyone who even now adds it up in their head, try it — it’s saved me a load of arguments with the bookie.
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