---
title: "What are the main security risks and hidden dangers of using letter of credit settlement for the entire process of entrepot trade?"
description: "Many foreign trade enterprises choose letter of credit (L/C) settlement in entrepot trade，but often encounter risks such as delayed foreign exchange receipt，loss of cargo rights and even compliance penalties due to insufficient control over soft clauses，cargo right transfer and compliance of third-party documents. By means of pre-reviewing L/C soft clauses，isolating cargo rights and settlement links，introducing third-party neutral supervision and other measures，risks can be effectively avoided，a..."
url: "https://www.sh-zhongshen.com/en/qa/core-security-risks-of-lc-settlement-in-entrepot-trade.html"
language: "en"
type: "Q&A"
category: "Entrepôt Trade Q&A"
datePublished: "2026-10-01"
dateModified: "2026-10-01"
brand: "Zhongshen Trading China"
answerCount: 9
---

# What are the main security risks and hidden dangers of using letter of credit settlement for the entire process of entrepot trade?

## Question

 I am the person in charge of a foreign trade enterprise engaged in Southeast Asian entrepot trade. Recently, we have a $500,000 rubber product order, and our overseas client insists on using L/C settlement. However, I heard from peers that some people encountered heavy losses because of hidden soft clauses in L/C for entrepot trade: they not only failed to receive the full payment, but also had their goods detained at the transit port. I am particularly anxious now. I want to ask: Is it really safe to use L/C for entrepot trade? Especially in our case where we need a third-party freight forwarder in Hong Kong to issue the full set of entrepot documents, will there be dual risks of losing cargo rights and delayed foreign exchange receipt? In addition, will the third-party document approval clauses in the L/C trigger customs compliance issues at the transit port or destination port? Last year, our batch of goods was detained by Thai customs for a week due to non-compliant third-party documents, and we lost more than 30,000 US dollars just in detention fees. Now we are really afraid of falling into the same trap again. 

## Answers
                            
### Answer 1 — Best Answer

Many foreign trade enterprises mistakenly believe that using L/C in entrepot trade is a "safety net"，which is a typical industry misunderstanding. L/C follows the surface examination principle of "strict compliance between documents and between documents and credit"，and does not review the actual flow of goods at all. If overseas clients collude with third-party freight forwarders to set hidden soft clauses in the L/C，the risks will be amplified.

For example，if the clause requires "NVOCC bill of lading issued by the client-designated freight forwarder as the negotiation document"，the freight forwarder can directly endorse the bill of lading to the destination port client afterwards. When the seller negotiates with seemingly compliant documents，the issuing bank may refuse payment on the grounds that "the bill of lading issuer is not registered with the issuing bank"，the goods have already been picked up，and the seller will also face chain reactions such as recovery of detention fees at the transit port，customs compliance investigations，and even being included in the foreign trade credit blacklist.

In terms of physical risk isolation measures，it is required to **specify in the L/C that the entrepot documents shall be issued by a neutral third-party institution**，and the consignee of the bill of lading must be the overseas agent designated by the seller，rather than directly writing the destination port client，to ensure that the cargo rights are always within our controllable scope.

Exclusive loss-mitigation tip: Sign a "cargo right custody agreement" with a professional foreign trade agency in advance. Once signs of issuing bank refusal to pay are found，immediately notify the transit port freight forwarder to detain the goods，and activate the alternative collection channel at the same time，so as to control the loss within 15% of the cargo value and avoid full loss.

**status:** accepted
**Author:** Cindy Chen
**Date:** 2026-10-01

### Answer 2

Under L/C settlement for entrepot trade, the core risk in the customs declaration link lies in the matching degree between third-party documents and L/C clauses. If the entrepot certificate of origin, bill of lading and other documents required by the L/C do not match the cargo value, product name and transit port information on the customs declaration form, the customs will launch a price review investigation, even认定为false declaration of trade mode, triggering penalties such as detention and fines.

During operation, all documents required by the L/C shall be submitted to the customs declaration department for pre-review in advance, to ensure that the "trade mode" column on the customs declaration form is accurately declared as "entrepot trade", and the cargo value shall be consistent with the settlement amount on the L/C, to avoid situations of "over-declaring low export" or "under-declaring high export". If customs price review questions are encountered, immediately provide supporting materials such as L/C copies, entrepot contracts and third-party freight forwarder agreements to prove the authenticity of the transaction, and avoid being included in the key supervision list.

**status:** suggested
**Author:** Jason Wu
**Date:** 2026-10-01

### Answer 3

The cargo right risk in L/C settlement for entrepot trade is mainly concentrated in the bill of lading transfer link at the transit port. If the L/C allows the client to designate the freight forwarder, the freight forwarder may directly endorse the order bill of lading to the destination port client, causing the seller to lose cargo rights.

During operation, it is required to clearly stipulate in the L/C that the bill of lading issuer is a neutral freight forwarder with NVOCC qualification, and the bill of lading must be an order bill of lading "To Order of Shipper", rather than "To Order of Issuing Bank" or "To Order of Client". At the same time, select an agent with long-term cooperation with us at the transit port for cargo right custody.

If the issuing bank refuses to pay, notify the transit port agent to detain the goods immediately to avoid the goods being picked up by the destination port client. In addition, confirm the free detention period of the transit port in advance to avoid detention fees caused by delayed negotiation.

**status:** suggested
**Author:** Andy Guo
**Date:** 2026-10-01

### Answer 4

Tax risks under L/C settlement for entrepot trade mainly involve cross-border related party transaction pricing and VAT compliance. If the settlement amount on the L/C differs greatly from the actual cost of entrepot trade (including cargo costs, transit fees, freight forwarder fees, etc.), the tax authority will认定 it as profit transfer, trigger BEPS investigations, and even require supplementary payment of corporate income tax and late fees.

During operation, ensure that the L/C amount is consistent with the entrepot contract amount, and all cost vouchers (such as purchase contracts, freight forwarder invoices, transit port fee receipts, etc.) shall be retained for inspection to prove the reasonableness of the transaction pricing. At the same time, if RMB cross-border settlement (CIPS channel) is adopted, the VAT deferral policy can be enjoyed, and there is no need to pay import VAT in advance, reducing capital occupation costs, but the transaction details of entrepot trade shall be filed with the tax authority in advance.

**status:** suggested
**Author:** Daniel Xu
**Date:** 2026-10-01

### Answer 5

The core of payment and receipt compliance for L/C settlement in entrepot trade lies in the information matching of SWIFT messages. If the information such as "transaction code", "trade mode" and "transit port" in the SWIFT message does not match the record information of the State Administration of Foreign Exchange (SAFE), it will lead to rejection of foreign exchange settlement or suspension of funds. During operation, the transaction information of entrepot trade, including L/C number, contract amount, transit port and destination port, shall be recorded in the SAFE's "Goods Trade Foreign Exchange Monitoring System" in advance.

The SWIFT message shall clearly mark "ENTREPOT TRADE", and the time interval between payment and receipt shall be controlled within 90 days to avoid being listed as a "concerned enterprise" by SAFE. If foreign exchange settlement suspension occurs, immediately provide supporting materials such as L/C copies, entrepot contracts and bills of lading to apply for manual review to SAFE, and ensure that funds arrive in time.

**status:** suggested
**Author:** Eric Zhou
**Date:** 2026-10-01

### Answer 6

Common risk soft clauses in L/C for entrepot trade include "inspection certificate issued by the client shall be used as negotiation document", "bill of lading shall be issued by the client-designated freight forwarder", "negotiation shall be confirmed by the issuing bank that the client has received the goods", etc. Such clauses completely violate the principle that L/C is "independent of the contract", and fully hand over the initiative of cargo rights and foreign exchange receipt to the client. During operation, before the L/C is opened, require the client to delete all soft clauses involving "client's unilateral confirmation" and "designated freight forwarder".

If the client insists on retaining them, add a supplementary clause that "the execution of soft clauses shall be witnessed by a neutral third-party institution". At the same time, sign the "Entrepot Trade Risk Indemnity Agreement" in advance. If foreign exchange receipt losses are caused by soft clauses, we can hold the freight forwarder or third-party institution accountable to reduce our own risks.

**status:** suggested
**Author:** Victor Sun
**Date:** 2026-10-01

### Answer 7

Under L/C settlement for entrepot trade, the on-site inspection risk at the transit port may cause goods to be detained, which will then invalidate the "latest shipment date" clause in the L/C. If the customs at the transit port requires container unpacking and inspection due to non-compliant documents, and the latest shipment date stipulated in the L/C has expired, it will lead to non-compliant documents and the issuing bank will refuse payment. During operation, submit the entrepot documents (such as certificate of origin, bill of lading, packing list) to the transit port freight forwarder for pre-review in advance, to ensure that the product name, quantity and weight on the documents are consistent with the actual goods.

If transit port inspection is encountered, immediately notify the issuing bank to modify the latest shipment date and negotiation date of the L/C, and at the same time require the freight forwarder to provide supporting materials such as inspection notices and on-site photos to explain the situation to the issuing bank and strive for favorable negotiation. In addition, purchase transit port inspection insurance to cover losses such as detention fees and inspection fees.

**status:** suggested
**Author:** Lucas Liu
**Date:** 2026-10-01

### Answer 8

Although entrepot trade does not need to apply for export tax refund, document filing under L/C settlement is very important. If the filing is incomplete, the tax authority will认定 it as false entrepot trade and trigger tax investigation. During operation, uniformly archive documents such as L/C copies, entrepot trade contracts, third-party freight forwarder bills of lading, transit port fee vouchers and payment and receipt water slips, and retain them for no less than 5 years.

If the tax authority launches a letter of investigation, submit all filed documents within 15 days to prove the authenticity of the entrepot trade. In addition, ensure that the capital flow of payment and receipt is consistent with the document flow, and avoid the situation of "collecting and paying on behalf of others", otherwise it will be listed as a key monitoring object of tax risks and affect subsequent cross-border trade business.

**status:** suggested
**Author:** Linda Gao
**Date:** 2026-10-01

### Answer 9

The supply chain risk of L/C settlement for entrepot trade mainly lies in the logistics connection and cost fluctuation at the transit port. If the transit port has situations such as overbooking and skipping containers, it will cause cargo delay, trigger the latest shipment date clause in the L/C, and then affect foreign exchange receipt. During operation, plan more than two transit routes in advance, such as selecting Hong Kong and Singapore as transit ports at the same time.

If logistics abnormality occurs in one port, switch to another port immediately. At the same time, incorporate the fluctuation of logistics costs into the settlement amount of the L/C, such as adding a clause that "if the transit port fee increases by more than 5%, the settlement amount can be adjusted accordingly" to hedge against cost risks. In addition, sign a "Logistics Guarantee Agreement" with a third-party logistics service provider. If foreign exchange receipt losses are caused by logistics delay, require the logistics service provider to bear part of the responsibility.

**status:** suggested
**Author:** Michael Zhang
**Date:** 2026-10-01

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