Knowledge of shipping documentation is critical for export compliance and enforcement professionals. According to the US Department of Commerce, one indicator of a possible export violation is an abnormal shipping route for a particular product or destination.1 This red flag can be identified through scrutiny of shipping documentation, including air waybills (AWBs).
AWBs are used for air cargo shipments, and act as a contract between shipper and carrier. AWBs are generated by the freight forwarder and indicate receipt of goods by the shipper, transportation conditions, and the agreement to deliver the goods at the destination. There are two types of AWBs, including the house air waybill (HAWB), which serves as a contract between the shipper and the freight forwarder, and the master air waybill (MAWB), which is a similar contract between the freight forwarder and the airline.2
In 2019, electronic air waybills (eAWB) became the default contract of carriage for all cargo airlines, completing a process begun in 2010 by the International Air Transport Association (IATA).3, 4 The use of eAWBs is, however, still country dependent. For example, Hong Kong accepts either the printed image or electronic submission of the eAWB and does not require a paper copy. Turkey also accepts either electronic submission or a printed eAWB, but if it is printed, requires copies of both sides of the document. Dubai will only accept the eAWB in its electronic form, while in Russia the traditional paper AWB is mandatory.5
For compliance professionals, knowledge of how to read an AWB and use it to track shipments can help identify diversion of a company’s exports from the intended recipient. The AWB number itself contains useful information, as the first three digits indicate the airline carrying the freight.6 Compliance professionals can also look up a given eAWB number for most shipments to identify the export’s shipment route. This can be done using numerous commercial service providers which offer data from numerous airlines in one place. 7, 8 For exports destined for a country which does not accept eAWBs, this information can be requested from the freight forwarder.
There are also several tools compliance professionals can use to research potential supply chain partners. eAWBs are processed via 23 different third-party messaging service providers known as cargo community systems (CCS), which may differ from airport to airport.9 In order to connect these various systems, IATA has implemented the Cargo Connect program to develop a web portal known as Enhanced Partner Identification and Connectivity (EPIC) to facilitate connectivity and streamline the eAWB handling process, allowing supply chain stakeholders to identify, research, and connect with partners.10, 11 As of August 2024, this service was being utilized by 15 different governments and Customs services, 102 airlines, and 13,000 freight forwarders.12 Finally, the IATA offers the StB Matchmaker service enabling eAWB stakeholders to look up airports, locations, airlines, freight forwarders, and ground handling agents around the world.13
Armed with these databases and their knowledge of their own company’s products, compliance professionals can avoid potential export violtations by identifying an export’s shipment route and assessing whether it is logical and consistent with information provided by the buyer. If not, this may be an instance of export diversion.
3 https://www.iata.org/en/programs/cargo/e/efreight/
4 https://www.iata.org/en/about/
5 https://www.iata.org/contentassets/4bc75639b37641ba88f2e81e5516a020/e-awb-acceptance-by-customs.xlsx
6 https://www.freightos.com/freight-resources/air-waybill-awb/
7 https://www.seabaycargo.com/air-tracking/
8 https://parcelsapp.com/en/awb-air-cargo
9 https://www.iata.org/en/programs/cargo/e/cargo-connect/
10 https://www.iata.org/en/programs/cargo/e/cargo-connect/
11 https://www.iata.org/en/services/compliance/epic/
12 https://www.iata.org/en/services/compliance/epic/
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