Trade-based money laundering is the laundering process whereby criminal proceeds are placed in the ordinary course of trade flows in and out of a country. It is a problem that does not want to go away, with industries contending as criminals try to turn the legitimate trade system into an illicit financial system for their criminal networks. Companies can fight back against TBML through detection and prevention measures.
The ability to understand and recognize these red flags can indicate suspicious trade activity, likely linked to TBML. They direct the compliance teams and regulators to concentrate most of their time and resources on the riskier-than-usual shipments or other trade details.
Companies should be aware of what red flags to look for in their specific industry, which can help to close down TBML operations and keep the global trading system honest.
Industry-Specific Red Flags
It is also essential to understand the industry-specific red flags, as their risks are much higher. The electronics industry reportedly accounts for 40% of all TBML cases globally. In more than 60% of cases detected in that industry, there were red flags of short shipping routes that did not make sense based on known supply chains. In commodity trades, and especially in and out of high-risk jurisdictions, in 45% of detected TBML schemes, there were certifications or documentation from anonymous shell companies.
Detection Methods and Tools
There are various methods and tools that companies can utilize to detect potential TBML red flags within their trade activities. TBML schemes can be challenging to uncover, so a multilayered approach is essential.
Detection Methods
Data Analysis and Transaction Monitoring: It will enable companies to monitor big data in trade transactions for any anomalies through the software’s parameter settings based on known red flags of TBML. This software is going to help compliance teams flag unusual patterns that might signal an attempt to launder money through international trade for further review.
Document Verification: In the case that any transaction or business has raised some red flags about potential TBML trade-based money laundering, the compliance team checks a detail of verification. This means that they look through invoices, bills of lading, and any other sort of documentation against public records and other data derived from trade to see if any inconsistencies can be noted, which would be deemed red flags, and so require an investigation.
On-Site Audits: Customers or their facilities can be surprise-audited to determine whether actual trade is happening or if documentation lines up with physical goods and their exact origin/destination.
Tools
Database screening: It enables the screening parties to trade against sanction lists, adverse media, and other open-source risk factors in public and private databases that red-flag issues. Matches need proper investigation.
Analytical Case Management: These involve potential TBML red flags for regulators and benefit from software that supports the entire detection process, including risk assessment, and secure documentation of audits and investigations.
Developing a Risk-Based Approach
Businesses should have a risk-based way of identifying and setting priorities for TBML red flags. Businesses are required to understand some of the elements that can bring in risks relating to this industry, country, and even customer profiles. The risk assessment that looks at all these factors helps drive the resources of compliance programs to those transactions and business partners with the highest risks of trade-based financial crime, like TBML. This is a risk-based approach that directs attention to adequate monitoring and investigating red flags instead of a strategy that is tailored for all situations.
Investigating Red Flags
Wherever trade data and documentation are considered, flags for TBML and potential indicators of suspicious activities lie, and then the authorities should conduct a thorough investigation. Immediate measures to explore matches to risk criteria will prevent these cases from remaining static.
Inquiries with business counterparts, surveys of shipping routes and facilities, researching counterparties, and other forms of due diligence are standard forms that investigations may take. The guidance of financial regulators on this aspect is to be referred to in the case of red flags that are riskier. In each case involving TBML, there are red flags. It is essential to collect enough evidence to support an inference on whether more regulatory action is required or not.
Training and Awareness
Employee training should be done regularly so that they understand the stages of trade-based money laundering and the company’s policies for reporting and reacting to them. Knowledge of red flag indicators enhances the skills required for detection and also provides a sense of ownership. Similarly, ongoing awareness programs remind the staff of their role in protecting the supply chain against threats such as TBML.
Suppose staff can identify even the subtlest signs of Trade-Based financial crime and react appropriately. In that case, such compliance programs have a powerful front line in defense against related trade-based money laundering red flags.