US REPORT: TRADE-BASED MONEY LAUNDERING

In his always informative and helpful blog, Kenneth Rijock directs one to the report from the US Governmental Accountability Office in April.  This report followed a study published by the GAO dated December 2019 (see an article about the study at https://www.jdsupra.com/legalnews/trade-based-money-laundering-gao-report-41307/) – https://www.gao.gov/products/GAO-20-314R

The latter includes presentation slides on the December study.

This new report examines –

  • what the available evidence indicates about the types and extent of international TBML activities;
  • the practices international bodies, selected countries, and knowledgeable sources have recommended for detecting and combating TBML; and
  • the extent to which ICE has effectively implemented the Trade Transparency Unit (TTU) programme and steps the US government has taken to collaborate with international partners to combat TBML.

GAO says that it analyed US agency and international body data and documentation, conducted a literature review, and interviewed U.S. officials and selected knowledgeable sources.

GAO recommends that DHS develop –

  • a strategy to maximize TTU program effectiveness; and
  • a performance monitoring framework for the TTU programme.

DHS concurred with the first, but did not concur with the second recommendation, citing data it already collects and challenges it faces.  GAO continues to believe the recommendation is valid, as discussed in the report.

The TTU is a programme involving 17 partner countries, the first being established in 2005.  The goal is to exchange trade data with partner TTU to allow agencies in each country to work together to better identify anomalies in trade data that may indicate TBML. For example, through the analysis of shared trade data, the partners may be able to determine if there is a discrepancy between the reported value of goods when they leave the US and the reported value of the goods when they arrive in the partner country (and vice versa).

https://www.gao.gov/assets/710/705679.pdf

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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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