Indirect Air Carriers (IACs), Certified Cargo Screening Facilities (CCSFs), and other businesses regulated by the Transportation Security Administration (TSA) face a complex and ever-evolving web of compliance requirements. Beyond TSA’s public regulations, businesses with air-cargo operations must navigate (as applicable) the Indirect Air Carrier Standard Security Program (IACSSP), the Certified Cargo Screening Standard Security Program (CCSSSP), and other TSA security programs, not to mention emergency amendments, security directives, and information circulars. In addition, businesses registered with Cargo Network Services (CNS) as Endorsed Cargo Agents and Authorized Intermediaries (CNS Agents) must comply with the requirements of the Cargo Membership Handbook, including those regarding dangerous goods (DG) training and branch disclosures. And if businesses offer shipments containing DG for air transportation, they are subject to the U.S. Hazardous Materials Regulations and applicable international standards, which are enforced in the U.S. by the Federal Aviation Administration.

TSA regularly inspects IACs and CCSFs, and CNS has recently increased enforcement of its DG training requirements. In fact, CCSFs are required to conduct their own “self-audits” on a regular basis. On one hand, this gives regulated businesses nearly real-time feedback on their compliance with these requirements. On the other hand, it can create a false sense of security—regulatory inspections are often not comprehensive in nature (i.e., TSA “backtrack” inspections that are shipment-specific) and leave many critical compliance requirements untouched. In addition, regulators have limited jurisdiction and do not ordinarily review commercial documentation, such as terms of service, air waybills, etc.

For these reasons, the Scopelitis Air Cargo Team has developed a Mock Air Cargo Desk Audit designed to assess your business’s compliance with key regulatory requirements and size up your commercial documentation. We work closely with in-house counsel and appropriate business representatives (such as the Indirect Air Carrier Security Coordinator) to review compliance documentation and data and reach findings that help identify vulnerabilities and shore up weaknesses. Not only does this help your team prepare for future inspections and audits by regulators, but it can also surface compliance lapses that may qualify for certain voluntary-disclosure programs, such as TSA’s Action Plan Program.

The hidden value in a Mock Air Cargo Desk Audit is the Scopelitis Air Cargo Team’s deep knowledge of enforcement trends and agency guidance that limits (in some cases) the regulators’ ability to assess civil penalties. When we identify a compliance lapse, we not only suggest corrective actions but also help you assess the gravity of the issue and the likely outcome of an enforcement case, ensuring a measured response. Additionally, regularly conducting a Mock Air Cargo Desk Audit could itself be viewed by regulators as a “corrective action” that justifies a reduction in a proposed civil penalty.

The scope, frequency, and cost of a Mock Air Cargo Desk Audit are all variable. The Scopelitis Air Cargo Team is available to discuss this option to help your business stay on the cutting edge of compliance with these important legal requirements.