Who is accountable when a traceability programme cannot prevent illicit goods from entering the market?

Accountability usually sits with the organisations that design, operate, and govern the certification process, not with the technology itself. If a programme cannot stop illicit goods, leaders need to review controls over identity, custody, validation, and oversight. Effective accountability means defining who signs off on data, who audits exceptions, and who responds when the process breaks down.

Why This Matters for Security Teams

When illicit goods slip through a traceability programme, the failure is rarely just a data issue. It is usually a governance issue spanning identity proofing, custody controls, exception handling, and auditability. Security teams are often asked to prove that a record exists, but the harder question is whether the record can be trusted when a supplier, intermediary, or system operator behaves outside policy. That is why accountability belongs to the organisations that design and operate the programme, not to the platform alone.

In practice, the risk shows up where validation is assumed rather than enforced. NIST’s NIST SP 800-53 Rev 5 Security and Privacy Controls treats traceability-relevant controls as a management problem as much as a technical one, while NHIMG’s Ultimate Guide to NHIs — The NHI Market shows why identity and privilege sprawl make oversight difficult in real environments. In the Schneider Electric credentials breach, the lesson was not simply that access existed, but that trust boundaries were too broad for the evidence chain to remain reliable. In practice, many security teams encounter traceability failure only after an exception has already become a market event, rather than through intentional control testing.

How It Works in Practice

Accountability in a traceability programme should be assigned across the full chain of responsibility. The entity that certifies product identity, the operator that records custody events, and the governance team that approves exceptions all have distinct duties. If one party can override data without review, the programme can still produce a trail, but not a trustworthy one. That distinction matters because regulators and auditors increasingly care about whether the control environment can resist tampering, not just whether records are present.

A workable model usually separates four functions:

• Identity assurance for suppliers, carriers, and system operators, so entities are known before they can assert provenance.
• Custody validation at each handoff, with signed events and time-stamped evidence.
• Exception governance, so manual overrides, backfills, and missing scans are reviewed instead of silently accepted.
• Independent audit and escalation, so failures are visible outside the operational team that created them.

This is where the NIST control family is useful: it pushes organisations to define roles, monitor activity, and retain evidence that can stand up to review. NHIMG’s research on non-human identities also matters here because many traceability workflows depend on service accounts, API keys, and integrations that act without direct human oversight. If those identities are over-privileged or poorly rotated, the programme may accept false events as legitimate. Current guidance suggests using least privilege, strong logging, and periodic reconciliation between physical custody and digital records. These controls tend to break down when multiple third parties share the same integration path because shared credentials and weak segregation make it impossible to attribute a bad event to a single accountable actor.

Common Variations and Edge Cases

Tighter traceability controls often increase operational overhead, requiring organisations to balance faster throughput against stronger assurance. That tradeoff becomes sharper in distributed supply chains, where exporters, logistics providers, customs brokers, and marketplace operators all touch the same record set. In those environments, no universal standard fully resolves accountability yet, so best practice is evolving toward explicit control ownership, signed attestations, and policy-backed exception workflows.

One common edge case is when a programme has good provenance data but weak enforcement at the point of entry. Another is when the system is technically sound but governance fails, such as when reviewers routinely approve exceptions without challenge. In both cases, the programme may appear compliant while still allowing illicit goods to enter the market. A second useful reference point is the NIST model for assigning protective controls to identifiable owners, which helps prevent the “everyone assumed someone else was checking” failure mode. The broader NHI lesson from Schneider Electric credentials breach is that integrity failures often begin with weak identity governance long before the final incident becomes visible. For traceability programmes, accountability is strongest when each exception has a named approver, a retained record, and a defined escalation path.

Related resources from NHI Mgmt Group

• Who is accountable when a blockchain implementation cannot satisfy a data erasure request under privacy law?
• How can organizations prevent NHI-related breaches?
• Where does cross-environment agent discovery fit in an IAM programme?
• Who is accountable when an IGA programme cannot prove least privilege?