What is Trade Based Money Laundering? (TBML Explained)

19 February 2024
One of the most common questions in financial crime compliance is what is trade-based money laundering? Trade-based money laundering (TBML) is a sophisticated method. It's used by criminals to disguise the origins of illicit funds through international trade transactions.
different notes and currencies
In this practice, individuals or entities exploit the complex nature of global trade to obscure the movement of money derived from criminal activities.

This form of financial crime poses significant challenges to financial institutions and regulatory bodies striving to ensure compliance with anti-money laundering (AML) regulations.

The nexus between trade finance, compliance, and TBML is critical in comprehending this intricate issue.

Here's why...

What is Trade-Based Money Laundering?

TBML is a method used by criminals to move illicit funds across borders by exploiting the complexities of international trade transactions. Criminals manipulate the trade process to obscure the origins of their funds and make them appear legitimate. By doing so, they integrate 'dirty money' into the legitimate financial system.

The Role of Financial Crime Compliance

Financial Crime Compliance, or FCC, involves the efforts made by financial institutions to prevent their services from being misused. This includes activities such as money laundering and terrorist financing.

Institutions must adhere to AML regulations and Know Your Customer (KYC) procedures to ensure the transparency and integrity of their operations. TBML challenges FCC efforts due to its intricate nature, making it crucial for financial entities to adopt robust compliance mechanisms.

Trade Finance: An Avenue for Money Laundering

Trade finance plays an essential role in global commerce by facilitating the movement of goods across borders. It involves various stakeholders, including importers, exporters, banks, and shipping companies.

Criminals exploit this intricate network to manipulate invoices, overvalue or undervalue goods, and create fraudulent transactions. These actions obscure the true nature of the funds being moved, effectively disguising illicit gains.

One common TBML technique involves over-invoicing or under-invoicing goods. For instance, imagine a criminal syndicate exporting electronic goods worth $100,000. Instead of declaring the accurate value, they might inflate the invoice to $150,000. The importing entity pays the exaggerated amount, and the extra $50,000 represents the laundered funds. Now seemingly originating from legitimate trade.

The Challenge of Compliance in TBML

Combatting TBML is particularly challenging due to its complexity and the involvement of many jurisdictions. Regulatory bodies, such as the Financial Action Task Force (FATF), continually update guidelines to help institutions detect and prevent TBML. Yet, the intricacies of trade transactions make it difficult to distinguish between legitimate trade and money laundering.

FCC teams within financial institutions must develop advanced algorithms and use data analytics to identify suspicious trade patterns. These patterns include consistent overvaluation or undervaluation of goods, frequent changes in counterparties, and unusual shipping routes.

In October 2016, Thomson Reuters introduced the Trade-based Money Laundering Detection (TRAC) solution. This addressed the challenges posed by TBML. TRAC combines advanced technology with comprehensive data sources to help financial institutions detect potential instances of TBML. By analysing trade data and flagging inconsistencies, TRAC enhances the ability of compliance teams to identify suspicious activities.

The TRAC platform integrates data from various sources, including trade finance records, shipping data, and financial transactions, enabling a holistic view of trade-related activities. This approach assists financial institutions in identifying high-risk transactions that could be linked to TBML.

Examples of Trade-Based Money Laundering

Let's take a look at common examples of TBML you should be aware of:

Black Market Value Manipulation

Criminals might manipulate the value of goods in the black market to help TBML. For instance, a criminal group might trade precious gemstones with an artificially low value on paper. This undervaluation allows them to move significant amounts of money across borders, masking their true intentions.

Phantom Shipping Transactions

In this scenario, criminals set up fictitious shipping companies and engage in fake trade transactions. They generate fake invoices and shipping documentation, making it seem like legitimate goods are being traded. The goal is to move money through these fabricated transactions while avoiding detection.

The Regulatory Landscape and Congressional Perspective

Global efforts to combat TBML have led to increased regulatory scrutiny. The Financial Action Task Force (FATF) has issued guidelines to assist countries in developing effective AML strategies. These guidelines stress the importance of cooperation between financial institutions, trade authorities, and law enforcement agencies.

In the United States, Congress has also acknowledged the significance of TBML. The Congressional Research Service (CRS) published a report (R44541) discussing trade-based money laundering and its implications. The report underscores the complexities of TBML and highlights the role of governmental agencies in addressing this issue.

Is There More to it?

Navigating the Complexities of TBML Trade-based money laundering represents a formidable challenge in the realm of financial crime compliance, trade finance, and regulatory compliance. Criminals exploit the intricacies of international trade to obscure the origins of illicit funds. This challenges the efforts of financial institutions and regulatory bodies to maintain the integrity of the financial system.

Efforts such as Thomson Reuters' TRAC solution and global regulatory guidelines show the commitment of stakeholders to combat TBML. The complexity of TBML necessitates sophisticated compliance mechanisms, data analysis, and international cooperation.

As trade continues to be a vital driver of the global economy, combating TBML remains essential to preserving the transparency and legitimacy of international financial transactions.

But this is just the tip of the iceberg.

Our Trade Based Money Laundering (TBML) and Sanctions Compliance course is a must for any professional to level up their working knowledge.


What is red flag in trade-based money laundering?

A red flag in trade-based money laundering refers to suspicious indicators or patterns in international trade transactions that might suggest attempts to conceal illicit funds. Examples include over- or under-invoicing, frequent changes in counterparties, unusual payment methods, and discrepancies in goods descriptions. Identifying these red flags helps authorities detect and prevent money laundering through trade activities.

What goods are vulnerable to trade-based money laundering?

Goods that are vulnerable to trade-based money laundering are typically high-value items with fungible qualities and subjective pricing. Things precious metals like gold, electronics, pharmaceuticals, and commodities like oil or agricultural products. Criminals exploit the complex pricing and valuation mechanisms of these goods to manipulate invoices and disguise illicit funds through fraudulent trade transactions.
Eager to learn more about Trade Based Money Laundering? Click below to find out more about Redcliffe Training’s Trade Based Money Laundering (TBML) and Sanctions Compliance course:

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