On 9 December, FATF, in collaboration with Egmont Group, has released a new report to help the public and private sector with the challenges of detecting trade-based money laundering. The report takes stock of current TBML risks and uses case studies to explain the ways in which criminals exploit trade transactions to move money, rather than goods. The report says countries should use national risk assessments and other risk-focused material to raise awareness with the public and private sector entities involved in international trade – including FIU, customs agencies, law enforcement, financial institutions, transport companies, importers and exporters, accountants and auditors.  Key recommendations include improving information-sharing of financial and trade data, and improving cooperation between authorities and private sector, including through public-private partnerships; and a key finding of the report is that greater awareness about all aspects of the trade process, including how different financing processes are managed, would likely increase opportunities to detect and successfully disrupt TBML.

[As an aside, I have always favoured the use of the more encompassing term “trade-based financial crime” when considering risks and undertaking risk assessment – as there is more to trade-based crime than just money laundering.  However, at least TBML is a recognised label.]


Factsheet for the private sector –


Factsheet for the public sector –


I had omitted the following link (as it did not seem to generate much interest!), but it seemed time to add it again and say that, if you would like to make a (polite) gesture and help me with my removal and computer costs, I have a page at https://www.buymeacoffee.com/KoIvM842y

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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