On 2 May, Homeland Security Today reminds one that some criminal and terrorist organizations use trade-based money laundering (TBML) to disguise illicit proceeds and fund their operations. These kinds of schemes can rely on misrepresenting the price, quantity, or type of goods in trade transactions. To help fight this practice, it says, ICE’s Trade Transparency Unit has partnered with 17 countries to exchange and analyse trade data – but a review by the Government Accountability Office (GAO) found this programme has faced challenges. It says that the GAO says that knowledgeable sources recommended various practices for countries to consider to combat TBML, which GAO has grouped into 5 categories involving partnerships and information-sharing, training and further research.  It also says that ICE has set up TTU in 17 partner countries with the goal of exchanging and analysing trade data to identify potential cases of TBML. While TTUs have played a role in some TBML investigations, GAO found the TTU program has experienced various challenges, including lapses in information sharing between ICE and the partner TTU, differing priorities between ICE and partner TTU in pursuing TBML investigations, and limitations in the data system that ICE and the TTU use.


The report is at –



If you’d like to help to contribute to the cost of the new laptop and desktop I have had to acquire, now that I am 5,000 miles away from my originals –

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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