Trade Based Money Laundering (TBML)

Introduction

TBML training provides a comprehensive overview of the methods, risks, and controls associated with trade-based money laundering. Participants will learn to identify, assess, and mitigate exposure.

• 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
  • Protecting government revenue

Stages of TBML

Our trade-based money laundering course breaks down the full lifecycle of TBML, showing how illicit funds are hidden, moved, and reintegrated through global trade flows:

• 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 is 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

Trade based money laundering training highlights how to assess risk across clients, institutions, and transactions, with real-world case studies and red flag indicators to strengthen detection and monitoring practices.

• 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 that sell on cash
    • Charities
    • Professionals – Lawyers
    • Case Study 1: Bank X failing to recognise the PEP factor in a client
    • Case Study 2: Company ABC, running a chain of restaurants, uses bank 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:
  • Analysing 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 training brings risk assessment, red flag recognition, transaction monitoring, and document analysis together, providing a complete framework for identifying and preventing trade-based money laundering.

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

Our trade-based money laundering and sanctions compliance training course is led by a highly experienced ex-banker with over 30 years in the financial services industry. This includes 22 years with HSBC Bank Middle East from 1991 until 2013. This expert has over a decade of proven expertise in designing and delivering high-level training programmes to professionals across the industry.

Starting his professional career as a credit analyst in HSBC, our trainer subsequently grew into several senior Relationship Manager roles. Working in a global bank provided him with a platform to establish all-around banking knowledge and skills.

He developed a particular niche in all areas of Commercial Banking, with a high degree of specialisation in Corporate Lending, Credit Risk Analysis, Trade Finance, Relationship Management and Corporate Banking Products. As a senior RM, our TBML course leader 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 became a full-time trainer within HSBC. He continued in this role 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, combined with sound commercial orientation, communication, and people skills, ensures delivery of effective results-oriented learning.

This specialist has refreshing delivery methods, keeping audiences keen on subject matter whilst delivering the message with effect. Alongside trade based money laundering training, he has led technical, product and behavioural courses to a wide audience base. Subjects included were 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.

Work has taken this expert 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 the UAE.

Redcliffe Training’s trade-based money laundering course provides in-depth knowledge of the various forms of TBML, drawing on real-world examples across financial crime. This includes money laundering, bribery and corruption, sanctions breaches, terrorist financing, tax evasion, and fraud.

Upon course completion, 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 sessions relying heavily on theoretical knowledge, trade-based money laundering training at Redcliffe integrates real-world scenarios and case studies, illustrating practical challenges and solutions in combating TBML.
• Our course leader is more than an academic. He has significant field experience working directly with businesses. This background allows him to share first-hand experiences and insights that carry immense value from a learning perspective.
• Course content is customised, putting the specific needs of the audience first. This tailored approach ensures wholly relevant material, directly applicable to participant needs.
• The course focuses on how TBML is used in international trade, providing a more targeted learning experience.

TBML training at Redcliffe 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

Trade based money laundering training is an intensive session, providing participants with a comprehensive overview of TBML. It also examines its intersection with wider 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 real-world challenges faced by credit officers, relationship bankers, and trade professionals.