| Trade-based money laundering has become one of the primary methods of funds transfer for criminal organizations and sponsors of terrorism. Stronger banking regulations have made this method more attractive as the funds can be hidden within seemingly legitimate trade activity. The TBML/FT typology can be extremely complex, however, and it can easily appear as legitimate trade activity to those unfamiliar with its intricacies. This paper reviews traditional and emerging methods of TBML/FT as well as common compliance program processes to determine the actions financial institutions can take to combat this activity. Trade-based money laundering techniques vary widely. Therefore, financial institutions cannot rely solely on compliance investigators to recognize them. Instead compliance programs must take a multifaceted approach and use all the resources available to them. The recommendations given are intended to enable financial institutions to identify TBML activity through industry-specific training, data analysis, and communication with other entities engaged in the fight against this method of value transfer. |
