On 22 December, an article from Clyde & Co considers the risks for freight forwarders and customs brokers identified in a recent paper on TBML published by FATF and the Egmont Group of FIU.  It says that, historically, TBML has been a highly effective way for organised crime groups and professional money launderers to disguise the proceeds of crime.  In fact, a 2006 FATF study of TBML described it as one of the top 3 methods used by criminals to launder the proceeds of their crimes.  The paper highlights a number of factors which together paint a picture where TBML still presents a significant money laundering or terrorism financing risk.  The article says that companies operating in sectors which are unregulated for AML purposes, such as freight forwarders and customs brokers, need to be alive to the potential risks to their businesses and livelihoods of being unwittingly caught up.

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

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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