A cargo can be protected by cameras, fences, access controls, and sophisticated systems. But it only takes one employee ignoring a procedure to put the entire operation at risk.

That is precisely why the Authorized Economic Operator (AEO) Program by the Federal Revenue Service does not evaluate just documents and processes. Certification also requires the company to develop a culture of security, compliance, and risk management throughout the entire logistics chain. And this culture begins with people.

If your company is an importer, exporter, carrier, logistics operator, bonded warehouse, port terminal, cargo airport, distribution center, or provides services to the foreign trade chain, this article is for you.

What is the AEO Program?

The Authorized Economic Operator (AEO) Program is an initiative by the Federal Revenue Service that certifies companies within the international logistics chain that demonstrate high standards of security, tax and customs compliance, risk management, and operational reliability.

More than just an acknowledgment, the certification represents a competitive advantage. Certified companies tend to experience greater agility in customs procedures, a reduction in inspections, priority in cargo clearance, and recognition by both national and international commercial partners.

However, achieving certification is only part of the journey. The real challenge is maintaining, on a daily basis, the standards that justified this recognition.

Written procedures are not enough

It is common for companies to invest time and resources in drafting policies, manuals, workflows, and internal procedures. These documents are indispensable, but alone, they do not prevent operational failures.

In practice, it is people who control access to facilities, check documents, receive visitors, release goods, log information into systems, identify suspicious behavior, and make decisions that directly impact the security of the logistics chain.

When an employee is unfamiliar with a procedure, skips a mandatory verification, or acts out of overconfidence, existing controls can lose their effectiveness. A procedure only protects the company when it is known, understood, and applied by those who execute it.

The human factor remains one of the greatest risks

Most security incidents originate from human error, rather than sophisticated criminal operations. Here are a few examples:

• Allowing a visitor to enter without following the identification procedure;

• Sharing access passwords to “speed up” an activity;

• Discharging or releasing cargo without completing all scheduled verifications;

• Ignoring a document discrepancy believing that someone else will fix it later;

• Providing information to a scammer posing as a supplier or client.

These situations may seem simple, but they can result in fraud, asset misappropriation, operational disruptions, financial losses, and non-compliance during audits. Therefore, companies that invest only in physical infrastructure or technology leave a critical vulnerability unaddressed: human behavior.

Training transforms procedures into culture

The goal of a training program is not merely to pass along information. It is to develop safe behaviors and establish a culture in which every employee understands that they play a role in protecting the logistics chain.

This behavioral shift strengthens the entire organization and significantly reduces exposure to operational risks.

Which training programs are required by the AEO Program?

While every organization has specific needs, certain topics are highly relevant for companies participating in the international logistics chain:

• Module 1 – Fundamentals

  • AEO Program

  • Supply Chain Security Culture

  • Employee Responsibilities

• Module 2 – Customs Compliance

  • Foreign Trade

  • Customs Compliance

  • Import and Export Documentation

  • Tax Classification

  • Rules of Origin

  • Customs Risk Management

• Module 3 – Security & Privacy

  • Physical Security

  • Information Security

  • Cybersecurity

  • Social Engineering

  • Data Protection

• Module 4 – Integrity

  • Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF)

  • Identifying Suspicious Cargo

  • Incident Reporting

  • Code of Conduct

• Module 5 – Operations

  • Cargo Security

  • Transport Security

  • Container Inspection

  • Vehicle Inspection

  • Seal Control

  • Business Partner Management

When these topics are integrated into a continuous awareness program, risks decrease and the organization strengthens its maturity in security and compliance.

What do Audits look for?

Another crucial aspect is the need to prove that the training sessions actually took place. During audits, the company may need to present evidence such as:

• Annual training schedule;

• Attendance and participation logs;

• Certificates;

• Learning assessments;

• Periodic refreshers;

• Completion rates;

• Training history per employee.

Keeping this evidence organized streamlines audits, strengthens corporate governance, and demonstrates the company’s commitment to continuous improvement and process compliance. Maintaining the AEO certification does not depend solely on internal policies and controls. It is sustained every day by the conscious actions of each employee.

How TothBe can support your company

TothBe develops specialized corporate training that helps strengthen the culture of security, compliance, and risk management required by the AEO Program. Through a multidisciplinary team dedicated to educational content development, we build solutions tailored to the needs and challenges of each organization.

In fact, several topics required by the AEO Program are already part of TothBe’s portfolio, including:

• Information Security and Cybersecurity;

• Social Engineering;

• Physical and Asset Security;

• Code of Conduct and Ethics;

• Compliance;

• Fraud Prevention;

• Whistleblowing Channel and Non-Retaliation;

• General Data Protection Regulation (LGPD);

• Anti-Corruption and Anti-Bribery;

• Onboarding and new hire integration.

All TothBe training programs include learning assessments, certificate issuance, participation records, indicator tracking, and management reports—generating the solid evidence your company needs to prove employee training during audits and maintain its AEO certification.

More than just meeting a certification requirement, investing in continuous employee training means strengthening supply chain security, reducing operational risks, and cementing a compliance culture capable of protecting the business over the long term.

Discover TothBe’s training solutions for certified companies or those undergoing the AEO certification process.

Talk to our experts: contato@tothbe.com.br