How trade-based laundering is actually detected

Working notes on typologies, red flags, regulation and detection, written for people who have to reconcile a trade and then defend the conclusion. Each brief cites the primary sources it rests on.

An aerial view of a loaded container ship under way at sea, with a tug alongside.
  1. 01

    5 min read

    Over- and under-shipment: reconciling what was billed against what was carried

    Quantity manipulation needs no price anomaly to work, which is why price benchmarking alone will never surface it. The reconciliation that does surface it uses weight, freight charges and container capacity to make the document set contradict itself.

    typologiesquantityshipmentreconciliation

  2. 02

    2 min read

    Trade Misinvoicing: The Mechanics Behind Illicit Flows

    Trade misinvoicing involves the deliberate falsification of the value, volume, and/or type of commodity in an international transaction by at least one party involved.

    explainerillicit-flowsmis-invoicing

  3. 03

    2 min read

    OFAC's Sanctions Architecture and Its Relevance to Trade-Based Risk

    OFAC is the U.S. Treasury office that administers sanctions programs and maintains country-specific sanctions information. OFAC sanctions programs can be either comprehensive or selective in scope.

    sanctionstransshipmentevasion

  4. 04

    5 min read

    Multiple invoicing: the anomaly that exists only between two files

    One genuine shipment, billed more than once, usually through different banks. No individual payment is anomalous, which is the point: the discrepancy exists only in a comparison nobody is assigned to make.

    typologiesmultiple-invoicingmis-invoicingdocumentary-credit

  5. 05

    5 min read

    Over- and under-invoicing: what a price benchmark has to control for

    A unit price is only high or low relative to a comparison. Most price-variance findings collapse because the benchmark ignored the incoterm, the quantity, the HS level, or the period, not because the price turned out to be defensible.

    red-flagsmis-invoicingpricingincoterms

  6. 06

    6 min read

    What is trade-based money laundering, and why it evades traditional controls

    Trade-based money laundering settles a real payment against a misstated fact. Every control in the chain can work exactly as designed and still not see the transfer, because no single control holds both records.

    fundamentalstypologiestrade-financedocumentary-credit