Trade Based Money Laundering (TBML)

Introduction

• Trainer/Delegates
• Course Objectives
• Course Topics
  • Introduction to TBML
  • Stages of TBML
  • Principal Methods of TBML
  • TBML Risk Assessment
  • TBML Controls

Introduction to TBML

• Definition of TBML
  • Financial Action Task Force (FATF) Definition
• Ways in which Money is Laundered
  • Using Banks
  • Smuggling
  • Trade-Based Money Laundering
• Extent of the TBML problem
  • Comparison of TBML with overall Money Laundering
• Regulatory Response
  • Catch and Penalise Criminals
  • Protect Government Revenue

Stages of TBML

• Placement
  • Conversion of illicit money into goods
• Layering
  • Goods moved across international borders
• Integration
  • Goods Resold in legitimate markets

Principal Methods of TBML

• Under/Over Invoicing
• Incorrect Quantity of Goods
  • Phantom Shipment
• Incorrect Quality of Goods or Services
• TBML using Gold as Goods
• Informal Money Transfers
  • Hawala – Falsifying Money Transfers
  • Black Market Peso Exchange
• Fraud in Trade
  • Transfer Pricing
  • VAT Fraud
  • Falsifying Documents
  • Accommodation Transactions
• Case Studies
  • Company X under invoicing to avoid tax
  • Company Y using Hawala to transfer funds from Country A to a Tax Haven country and make it appear legitimate by transferring back to Country A as business income

TBML Risk Assessment

• Assessment of Risk on Trade Transactions
  • Knowing who the Client is?
    • Financial Institutions/Correspondent Banks
    • Non-Banking Financial Institutions
    • Money Exchanges
    • Casinos
    • Politically Exposed Persons (PEPs)
    • Businesses selling on Cash
    • Charities
    • Professionals – Lawyers
    • Case Studies
      • Bank X failing to recognise the PEP factor in a client
      • Company ABC, running a chain of restaurants, using banks accounts to launder money by making the cash deposits appear as sales revenue from restaurants
    • Recognising the Red Flags
      • Client Behaviour
      • Connected Parties
        • PEPs
        • Shell Companies
        • High Risk Jurisdiction Companies
        • Related Companies
      • Monitoring the Transactions
        • Analyzing financial information
          • Aligned with normal business activities?
          • Origin of Inward and destination of outward remittances
        • Trade Documents
          • Frequent requests for amendments
          • Missing documents
          • Goods shipped through high risk or sanctioned countries

TBML Controls

• KYC Profile and TBML
• Customer Due Diligence
• 1st Line of Defence – Front Office
• 2nd Line of Defence – Risk/Compliance Unit
• 3rd Line of Defence – Internal Audit
• Training

The trainer is a highly experienced ex-banker with 30 plus years’ experience in the financial service industry, including 22 years with HSBC Bank Middle East from 1991 until 2013. The trainer carries with himself an overall experience of delivering training programs for more than 10 years.

The trainer began his professional career as a credit analyst in HSBC, and subsequently grew into several senior Relationship Manager roles. Working in a global bank provided him a platform to establish all-round banking knowledge and skills. He developed a particular niche in all areas of Commercial Banking, with a high degree of specialization in Corporate Lending, Credit Risk Analysis, Trade Finance, Relationship Management and Corporate Banking Products. As a senior RM, he managed a portfolio of clients in various industries and of various sizes, including large corporates and sovereign entities, with a combined credit limit of USD 500M.

In 2008, he turned into a full-time trainer within HSBC, a role in which he continued until 2012, when he parted ways with HSBC and started pursuing independent financial consultancy and training delivery. Possessing excellent technical knowledge on an extensive range of commercial banking businesses and products, which combined with sound commercial orientation, communication, and people skills, ensures delivery of effective results-oriented learning.

The trainer has a refreshing method of delivery which keeps the audience interested in the subject and delivers the message effectively. He has delivered technical, product and behavioural courses to a wide base of audience on subjects such as Financial Analysis, Credit Risk Management, Managing Problem Loans, Writing Credit Proposals, Trade Finance, Anti-Money Laundering/Compliance, Project Finance, Islamic Finance, Sales and Negotiation Skills and Relationship Management.

His work has taken him to deliver courses in the wider GCC, MENA, Europe, Latin America and Asia Pacific regions thus giving him an exposure to the various cultural and professional approaches to work. He has also completed trainer accreditation programmes from Hong Kong and UAE.

This training is aimed to impart knowledge related to the various types of trade-based money laundering, derived from the different forms of financial crime such as Money Laundering, Bribery and Corruption, Sanctions and Terrorist Financing, Tax Evasion, and Fraud.

Upon the completion of this course, the participants will be able to:

• Describe the objectives, incentives and methods of trade-based money laundering
• Identify the key risks related to trade transactions from a money laundering perspective
• Mitigate key risks by establishing appropriate controls within any organisation

• Unlike courses that rely heavily on theoretical knowledge, our program integrates real-world scenarios and case studies that illustrate practical challenges and solutions in combating TBML.
• The instructor is not just an academic but has significant field experience working with businesses. This allows him to share first-hand experiences and insights that carry immense value from a learning perspective.
• The course content has been customized bearing the specific needs of the audience. This tailored approach ensures that the material is always relevant and directly applicable to the needs of the delegates.
• The focus of the course is deeply on how TBML is used in international trade, providing a more targeted learning experience.

This TBML Course is applicable for;

• Credit and risk officers
• Corporate relationship bankers
• Transaction banking sales and product specialists
• Professionals working in trade functions of banks and corporates

This intensive one-day training course provides a comprehensive overview of Trade-Based Money Laundering (TBML) and its intersection with broader financial crimes such as bribery, corruption, sanctions evasion, tax fraud, and terrorist financing. Designed for professionals in banking and trade finance, the programme explores the objectives, methods, and risks of TBML, while offering practical strategies for risk mitigation and compliance. Through engaging lectures, case studies, and discussions, participants gain actionable insights into TBML risk assessment and control mechanisms. The course is led by a seasoned industry expert and tailored to the real-world challenges faced by credit officers, relationship bankers, and trade professionals.