On 6 January, a news release from AUSTRAC in Australia says that, in trade-based money laundering (TBML), criminals take advantage of the size and complexity of international trade to transfer money between parties and evade authorities.  Techniques include mismatching the value of the goods and payment (over- or under-pricing relative to market value, quantity or quality), issuing multiple invoices for a single shipment or sending no goods at all; and developing countries are particularly vulnerable.  Acknowledging that no single body can tackle such challenges, AUSTRAC has been taking a collaborative approach.  It established the Fintel Alliance in 2017, the world’s first private-public partnership of its kind, with 28 members which include experts from financial industry, intelligence agencies, law enforcement, and academic and research institutions.  Along with improved operational outcomes, members’ capability increases as partners learn from one another and synthesise knowledge. Fintel Alliance has now formed a TBML working group that includes front line experts from industry and law enforcement to develop indicators and typologies that can be broadened to other jurisdictions and trade types.  The article also mentions that a joint FATF-Egmont Group project on TBML included AUSTRAC-led input and there were substantial contributions from private and public Fintel Alliance members to the development of the project’s final report.

If you would like to make a (polite) gesture and make a (very) modest contribution to my ongoing with my relocation, 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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