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18 December 2020, 13:06


Trade compliance and Trade based Money Laundering are hot topics in 2021


To goal of this article is to raise awareness of TBML risks.

Trade can be complex and complicated, reflecting the nature of supply chains stretching around the world.

As identified in the recent  FATF’s 2018 Professional Money Laundering reportTrade-based Money Laundering is one the methods most preferred by Money-launderers and is often combined with the use of front companies, front men, and other ML techniques.

Trade-based money laundering is highly adaptive and can exploit any sector or commodity. These are exploited by  Professional Money Launderers  and Terrorist Financing networks, to facilitate myriad types of financial flows, including the laundering of proceeds of crime, such as from drug trafficking; the financing of terrorism; and the evasion of sanctions.

To goal of this article is to raise awareness of TBML risks.
As we are  due to Covid 19 less cash these days, national lockdowns have made it maybe harder for criminals to move cash across borders as there is a trend that TBML is on the rise in cashless societies and those who have been highly impacted by national lockdowns and Brexit

One criminal network using TBML was able to move $ 400m over several years.

Marcus Pleyer FATF President

What is Tradebased Money Laundering ?

Trade-based money laundering is defined as the process of disguising the proceeds of crime and moving value through the use of trade transactions in an attempt to legitimize their illicit origins.

The traditional techniques were described in the initial 2006 FATF report and include: under- or over-invoicing of goods; under- or overvaluation of goods, and/or phantom shipments, where no goods move at all.

These continue to be used for ML purposes as they are highly flexible and adaptable, despite changes in global trading patterns and the growth of new markets. These techniques are particularly effective when there is a complicit relationship between the importer and exporter, who are actively misrepresenting an aspect of the trade or the associated invoice settlement process. Therefore, authorities can have a greater impact if they can disrupt these complicit actors, whether through criminal prosecution or another form of disruption – e.g. removing their authority to trade

How does trade based money laundering work?

TBML can involve the import and export of goods and the exploitation of a variety of cross-border trade finance instruments.

Examples of Trade Based Money Laundering

3 very common methods relate directly to invoicing these are called over-invoicing, under-invoicing, multiple-invoicing, and relate directly to charging a different amount than is due for the goods/services in question.

Another method, related directly to this, is often to misrepresent the quality of the goods in question to leave a gap between value or cost and the amount paid.

Recently in the media were also 4 COVID-19 not related common methods:

  1. Potatoes, Onions and other fruits are bought conventionally in Germany and were exported to a company in Africa, but invoices directed large payments to accounts controlled by drug traffickers
  2. Fruit exports from New Zealand were paid by third-party shell companies, the fake invoices shown to banks called the shipment as “ceramic tiles
  3. Luxury cars were sold across borders by criminals with low values declared before the shipment. They were repaired and resold at near their undamaged prices
  4. Watches bought in Spain and Switzerland by export and import companies were used to transfer value to drug traffickers in Morocco and the Netherlands


How can firms combat Tradebased Moneylaundering?

The right transactions monitoring system in place that uses all your data points makes it much easier to find suspicious cases in the case of trade-based money laundering.

How can trade based money laundering be reduced?

An effective compliance program that includes a Tradebased Moneylaundering Transactions monitoring system can reduce the risk within your organization.

Is TBML also taking place in unregulated sectors ?

Non-financial companies who might not be regulated have to comply with money laundering, bribery and other (financial) crime legislation and are therefore a target of potential TBML risks as not all TBML involves trade finance.

Does TBML occur in the Media ?

It is a hot topic in the media. Recently the FT Weekend published an article on 2. January 2021  by Matthew Vincent covering Trade-based money laundering.
Covering latest trends and over and under-invoicing of products and also topics mentioned in the december 2020 issued report on TBML

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