The European Commission has released new guidance titled “AEO – Customs Cooperation to Detect, Report and React to Suspicious Activities”, marking an important evolution in how illicit trade, drug trafficking, and organised crime are addressed across the EU.
While non-binding, this guidance provides a practical framework for cooperation between customs authorities and businesses, signalling a broader shift toward more proactive and structured collaboration in supply chain security.
A New Model of Customs-Business Cooperation
Traditionally, customs enforcement has relied heavily on authorities identifying risks at borders. However, the new EU guidance recognises a critical reality:
Businesses are often the first to detect suspicious activities within supply chains.
The document therefore promotes a model where economic operators actively contribute to identifying and reporting risks, complementing customs controls.
This approach builds on the principles of the Authorised Economic Operator (AEO) programme but extends expectations beyond certified operators to all businesses involved in international trade.
Key Features of the EU Guidance
1. Proactive Reporting of Suspicious Activities
One of the core elements of the guidance is the encouragement for businesses to report not only confirmed irregularities but also suspicions.
This includes:
- Unusual shipment patterns
- Inconsistencies in documentation
- Suspicious behaviour from partners or employees
Early reporting enables customs authorities to act faster and prevent illicit activities from escalating.
2. 24/7 Customs Contact Points
To support timely communication, the guidance promotes the establishment of dedicated 24/7 contact points within customs authorities.
This ensures that:
- Urgent alerts can be shared without delay
- Businesses have clear channels for escalation
- Time-sensitive risks are addressed immediately
3. Two-Way Information Sharing
The guidance emphasises structured, two-way communication between customs and businesses.
This includes:
- Businesses sharing intelligence on suspicious activities
- Customs providing feedback and risk insights
- Continuous exchange to improve detection capabilities
This dynamic interaction enhances overall supply chain visibility.
4. Secure Whistleblowing Mechanisms
Recognising the risk of insider involvement in illicit trade, the guidance encourages:
- Anonymous reporting channels
- Internal whistleblowing systems within companies
- National-level reporting mechanisms
These tools aim to uncover internal threats that might otherwise go undetected.
5. Continuous and Adaptive Cooperation
Rather than one-off reporting, the guidance promotes ongoing dialogue between stakeholders.
This allows:
- Detection strategies to evolve alongside criminal tactics
- Businesses to stay informed of emerging risks
- Authorities to refine targeting methods
Implications for Businesses
Although the guidance is not legally binding, it clearly indicates the direction of future EU customs policy, particularly in light of the upcoming reforms to the Union Customs Code (UCC).
The European Commission’s new guidance represents a subtle but meaningful shift in customs strategy.
It moves beyond general cooperation principles and begins to define how businesses and customs authorities can work together in practice to combat illicit trade.
As the EU continues to modernise its customs framework, companies that embrace this collaborative approach will be better positioned to navigate future regulatory developments and contribute to a more secure global trade environment.