Trade Based Money Laundering (TBML)

Introduction

Trade-based money laundering training provides a comprehensive overview of the methods, risks, and controls associated with TBML. 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
• How 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

TBML training breaks down the full lifecycle, 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

• 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

This trade based money laundering course highlights the assessment of risk across clients, institutions, and transactions, using 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 is included in TBML training
• 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

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

A highly experienced ex-banker leads Redcliffe’s TBML course with over 30 years in the financial services industry. He served 22 years with HSBC Bank Middle East from 1991 to 2013 and has over a decade of proven expertise in designing and delivering high-level training programmes for industry professionals.

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

Developing a particular niche in all areas of Commercial Banking, he has a high degree of specialisation in Corporate Lending, Credit Risk Analysis, Trade Finance, Relationship Management and Corporate Banking Products. As a senior RM, our trade based money laundering course leader managed a portfolio of clients in various industries and sizes, including large corporates and sovereign entities, with a combined credit limit of USD 500M.

In 2008, this specialist became a full-time trainer within HSBC and continued this role until 2012, when he began pursuing independent financial consultancy and training delivery. He has excellent, extensive technical knowledge of a range of commercial banking businesses and products. Combined with sound commercial orientation, communication and people skills, this ensures effective results-oriented learning.

Our TBML training expert uses refreshing delivery methods, keeping audiences on subject matter whilst delivering effective messaging. He has led technical, product and behavioural courses for a wide audience base with subjects including 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 includes delivering training in the wider GCC, MENA, Europe, Latin America and Asia Pacific, giving him exposure to various cultural and professional approaches to work. He has also completed trainer accreditation programmes from Hong Kong and the UAE. Drawing on this extensive international experience, delegates benefit from practical, globally informed insight throughout this TBML course.

Sessions provide in-depth knowledge of the various TBML forms, drawing on real-world examples across financial crime. Training includes money laundering, bribery and corruption, sanctions breaches, terrorist financing, tax evasion, and fraud.

Upon completion of Redcliffe’s trade based money laundering training, participants will be able to:

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

This TBML course is designed for professionals involved in trade finance, financial crime prevention, risk management, and corporate banking, including:

• 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. Participants receive a comprehensive overview of TBML.

We examine its intersection with wider financial crimes, including 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, and offers 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.

TBML training is led by a seasoned industry expert and tailored to real-world challenges faced by credit officers, relationship bankers, and trade professionals.