There are few public agencies in which the classic preconditions for institutional corruption are so conveniently presented as in a customs administration. The potent mixture of administrative monopoly coupled with the exercise of wide discretion, particularly in a work environment that may lack proper systems of control and accountability, can easily lead to corruption. Customs officers often have extremely low salaries compared to what people are able to acquire through illegal activities. The frequent need to work in highly decentralised locations, such as cargo sheds and remote border posts make direct supervision and accountability difficult to maintain. Customs officials and those that deal with them are, therefore, particularly vulnerable to corruption.
In the US, company officials, officers, directors, and stockholders acting on behalf of the firm who wilfully violate anti-bribery laws can be subject to fines of up to $100,000 and imprisonment for up to five years. Whilst firms are subject to fines of up to $2 million.
How can we help a client to prohibit facilitation or service payments to customs officers? There are no quick or simple solutions. We can help companies set up compliance and training programmes and conduct internal investigations. We can improve supervision and accountability. We can assist clients to achieve high levels of integrity by devising policies to ensure the utmost utilisation of automation. We can help implement and promote: sound human resource management systems, including rotation and relocation of staff from high-risk working environments; the strengthening of audit and internal investigation systems; and codes of conduct and disciplinary procedures.