On 19 April, an article from White & Case says that governments worldwide are sharpening their focus on money laundering executed through international trade.  Companies active in international trade, regardless of where they are located, should take notice as their supply chains continue to come under greater scrutiny, as international attention on trade-based money laundering continues to grow.  The article also mentions a corollary process called Trade-based Terrorist Financing (TBTF), which uses the same processes as TBML to finance terrorism, but the value moved can come from both legitimate and illegitimate sources. It is important, it says, to note that the aim of TBML/TBTF is the movement of money, and the movement of goods is the mechanism for obscuring the true origins or purposes of the money.  One of the article’s conclusions is that, while most such companies do not have specific obligations to address TBML/TBTF yet, the expectations on such companies continue to rise, as AML stakeholders understand the value such companies hold to understanding and combatting TBML/TBTF.

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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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