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Ability to audit Amazon’s Business to Consumer [B2C] transactions at scale
Why is this project important?
The ability to audit at scale is critical to identifying compliance gaps and measuring risks across our B2C lanes. Customs authorities
expect effective internal controls to be in place that for those operators managing movements at scale. To proactively identify
compliance errors and resolve them with the relevant authorities, we are targeting to implement a full audit program for B2C
transactions by Dec ‘22. We have successfully used our audit processes to make proactive disclosures with our [non-B2C] retail brokers.
In 2019, for example, we identified an issue with underpayment of ~$1.4M duties/VAT for ~3000 declarations [spanning the years
2017-2019] and resolved this issue through upstream fixes and proactive disclosures.
Scaling our audit processes relies on the availability of broker data and automation. Without this, we are limited to manual checks
that can only give an initial indication of the compliance levels. Our auditor performed an initial manual check on a sample of 400
Remote Fulfillment shipments, results from this preliminary check identified 49 inaccurate declarations [12% error rate]. Although
based on a limited sample, the data is indicative that an audit process at scale could have a significant impact on improving compliance.
On the back of the findings from our sample audit, we are looking to scale our framework to all retail remote fulfilment transactions
with urgency and expand this to cover core exports and other B2C channels [ETA: 30 Sept], see detailed plan in Appendix.
How will 1 BIE and 1 Data Engineer enable us to audit at scale?
In order to automate our audit processes, we need to copy the data exchange structures that were built for retail brokers and
implement controls. While we already have established processes in place for retail brokers, the B2C channel brings increased
complexity: we have 16 B2C brokers [vs. 3 retail brokers]. We will need to: 1] coordinate with each broker individually [we anticipate
that some brokers may not want to work with us and/or will require changes to their contractual terms]; 2] build data pipelines; 3]
create tables; 4] build 16 individual ingestion points; 5] automate broker metrics/KPIs;6] automate process of disclosures; and 7] build
auto audits for valuation, Harmonized classification codes (HS) and Country of origin (COO). This effort will require] 2 HC [1 Business
Intelligence Engineer and 1 Data Engineer]. The DE HC will be dedicated to setting up the data infrastructure( data warehouse) and
BIE HC towards reporting metric and building automated builds.
30
31
Appendix - Audit at Scale - Broker Data Ingestion Points project plan
No
Action
1
Audit Requirements defined
1.1
1.2
1.3
2
2.1
2.2
2.3
2.4
3
3.1
3.2
3.3
4
32
Identify what data is
required from Brokers to
conduct audits
Define audit requirements
for manifest database and
supporting
evidence
required for audits
Send list of data fields to
Global Mile team
Broker engagement and
data requests
Global Mile to define a plan
for requesting data from the
16 brokers supporting B2C
lanes
If necessary, change broker
contracts to ensure they are
providing the data required
for audits
Establish SLA and frequency
of data upload with brokers
Global Mile to deliver sample
data for validation checks in
CSV and JSON
Broker Data Validation and
resolution
Review
broker
data
delivered by global Mile for
completeness and address
data gaps
Data validation confirming
accuracy of broker data
against declarations
Resolving
data
gaps
identified by validation
Global Mile/GTC to create
Manifest database
Owner [Team]
Claudia Macin [Trade
Compliance]
Comments
Complete
Navdeep Singh [Trade
Compliance]
Complete
Claudia Macin [Trade
Compliance]
In Progress
SADs document repository [Tabelerium] to support document
reviews.
Complete
Meeting with GM team held on March 03
Navdeep Singh [Trade
Compliance]
Alistair Moody [Global
Mile]
30
April
2022
Alistair Moody [Global
Mile]
01
April
2022
Procurement POC TBD
TBD
Alistair Moody [Global
Mile]
30
April
2022
Alistair Moody [Global
Mile]
30
April
2022
Navdeep Singh [Trade
Compliance]
30
June
2022
Nitin Kumar
Compliance]
[Trade
31
May
2022
Claudia Macin [Trade
Compliance]
31
May
2022
Alistair Moody [Global
Mile]
30
June
2022
30
June
2022
30
September
2022
30
September
2022
30
September
2022
30
September
2022
31 October
2022
30
September
2022
TBC
5
Onboarding Brokers to
Customs Central Platform
Ananth
N[
Compliance]
Trade
5.1
Design and build
results dashboard
Nitin Kumar
Compliance]
[Trade
5.2
Setup data pipeline & build
ingestion points for broker
data
Nitin Kumar
Compliance]
[Trade
5.3
Design and build audit
automation workflow
Nitin Kumar
Compliance]
[Trade
6
Launch Audit Execution and
Reporting
Claudia Macin [Trade
Compliance]
6.1
Build audit SOP
Claudia Macin [Trade
Compliance]
6.2
Hire and train skilled audit
team and kick off audits
[report outcomes and track
metrics]
Claudia Macin [Trade
Compliance]
audit
ETA
31 October
2022
Dependency on feedback from the brokers
Dependant on HC [1 x BIE + 1 data engineer]
Dependant on HC [1 x BIE + 1 data engineer]