On 22 December, Clyde & Co published an article which looks at risks for freight forwarders and customs brokers identified in the recent paper on TBML published by FATF and the Egmont Group of FIU.  It says that, historically, TBML has been a very 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 three methods used by criminals to launder the proceeds of their crimes.  The 2020 paper from FATF and the Egmont Group highlights a number of factors which together paint a picture where TBML still presents a significant ML or TF risk.  The article considers the most significant risk that freight forwarders and customs brokers may be exposed and what can be done to mitigate it.

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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