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This paper aims to offer the first known synthesis of peer-reviewed literature on trade-based money laundering (TBML). Given the topic is in its nascent stage yet gaining prominence across scholarship and practice, this foundation is pertinent for future TBML research.

A systematic literature review was undertaken with a formulaic search string. Both qualitative (thematic) and quantitative (meta) analysis methods were used to illustrate the findings.

The systematic literature review, using qualitative and quantitative synthesis, led to a thematic categorization of extant TBML literature into four categories: TBML risk assessment, TBML detection, the role of professionals and understanding of TBML. Due to the limited number of studies, insights that can be drawn from the extant literature on the best way to combat TBML are also limited.

As the first systematic literature review on TBML, this study identified that the existing TBML literature has focused on increasing the understanding of the phenomenon in terms of its definition and mechanisms, detection, linkage with other crimes, such as organized crime and terrorism financing, and risk assessment frameworks. The originality of these findings lies in identifying areas future researchers might explore to broaden the academic literature.

The purpose of this study is to apply the regulatory dialectic to describe the evolution of trade-based money laundering (TBML) schemes, to describe three recent TBML innovations uncovered by a large bank in the important global trade jurisdiction of the United Arab Emirates (UAE), and to provide recommendations for an effective regulatory response.

The methodology used is a caselet approach with three examples of TBML schemes recently foiled in the UAE as well as an application of the regulatory dialectic literature to TBML.

The implications of the regulatory dialectic for research regarding TBML and associated regulation and compliance will enable regulators, the financial services sector and academics to understand TBML and the ever-evolving steps criminals are taking to circumvent the changing landscape of regulation and controls implemented by the financial services sector and customs tasked with mitigating such behaviour. This paper will bring awareness of the evolution of TBML, the controls and frameworks that may be used to prevent, detect and investigate some of the complex schemes of TBML.

The regulatory dialectic theory provides insights into the evolution of TBML schemes as well as why compliance activities tend to be reactive, rather than proactive. The cases covered in this paper provide insights into the nature of this circular process between financial crime and regulation, which is useful for anti-financial crime professionals and regulators focusing on deterrence.

The UAE is a small, rapidly developing trade and finance center in the Middle East, surrounded by nations that are sanctioned, in active conflicts, politically unstable and/or highly corrupt. TBLM undermines the security of the UAE; the authors provide insights into criminal innovations and regulatory responses.

To promote the safety and stability of the ten million residents of the UAE, and others in the Middle East and North Africa (MENA) region, it is important to understand the process of innovation in TBML schemes and regulatory response.

To the best of the authors’ knowledge, this paper is the first to apply the regulatory dialectic theory to TBML to describe innovation in TBML schemes and to provide cases describing contemporary TBML innovations in the MENA region.

Money laundering (ML) has become a significant challenge all over the world today. Trade-based money laundering (TBML) is a type of ML that poses a hazard to any country. In recent years, developed and developing countries have pursued liberal policies for international financial markets. The Financial Action Task Force (FATF) defines TBML as the process of concealing criminal earnings and shifting value through trade transactions in an attempt to justify their illicit origins. As international financial markets have improved ML controls, criminals have turned to the trade sector as a new venue, raising trade risks. The purpose of this study is to highlight the danger posed by TBML and the initiatives that should be taken to prevent such.

A review of publicly available reports, case studies, secondary data and literature on TBML from a variety of Sri Lankan and international contexts comprised the methodology. However, due to the dearth of literature on TBML details/information in the Sri Lankan context, international case studies have been analyzed. More critically, there are no precise estimates of TBML or defined protocols for collecting and maintaining TBML data. As a result, the FATF potential TMBL typologies were analyzed, and typical TBML procedures were examined to identify viable treats for Sri Lanka.

The study found that TBML has a significant effect on the economy and, as a result, social conflicts. Sri Lanka has the potential for TBML, and ML through financial institutions was identified as a major risk. Literature, on the other hand, shows that a large quantity of money has been laundered using TBML in Sri Lanka. The geographical location entices criminals to wash their illicit gains, and so the country has potential danger from South Asian countries. However, because of the sociopolitical climate in Sri Lanka, criminals are constantly looking for ways to profit illegally. Relaxing rules to promote foreign investment may encourage launderers to use their illicit proceeds. The government needs to take great care when dealing with this particularly delicate issue.

Due to the complexity of financial crimes, this study had a number of limitations, as do many others. The data used for this study was sourced from publicly available information and the TBML has been clearly defined or understood due to the fact that the complexity of the methods used by criminals. As a result, the number of local instances reported on TMBL is quite small, hence this study relied on international case studies.

This research on TBML in Sri Lanka is original. It is anticipated that the findings and contribution of the study would help the stakeholders develop TBML prevention measures.

The purpose of this paper is to examine the link between trade-based money laundering and organized crime. Trade-based money laundering (TBML) has emerged as the newest and possibly most complex method used by organized crime and white-collar crime groups for illegally laundering money in the international financial system. Using legitimate global trade streams, criminal organizations are able to transfer billions of dollars annually between jurisdictions without having to adhere to state-level currency regulations.

Using a rational approach to understanding the behavior of criminal organizations, it is argued that TBML will continue to grow as a preferred methodology for laundering money internationally. As criminal organizations continue to be displaced from the more traditional methods of money laundering, they will look for and find TBML as a viable alternative for moving money between different jurisdictions.

As the methodology becomes more developed, the skill set will transfer to an increasing number of organized crime groups and be incorporated as a mainstream method for laundering and moving money.

To stay current with contemporary money laundering schemes, law enforcement agencies will have to train their investigators to spot, investigate and collect requisite evidence for successful prosecution and disruption of TBML offences. Moreover, in the absence of a global regime for sharing trade and customs information, legislators and law enforcement agencies will have to consider how to best expedite the sharing of trade and customs information.

This is the only study to address TBML as an emerging money laundering technique and the transfer of the skill between organized crime groups. It further details the skills that police investigators needs to develop to successfully combat TBML.

The purpose of this paper is to broaden the discussion on trade-based money laundering (TBML). The literature is too narrowly focused on the misrepresentation of the value, quantity or quality of the traded goods. This focus leads to the analysis of price anomalies as a signal of over- or under-invoicing. However, TBML can also occur without manipulation of these factors.

A review of the literature and case study of police investigations.

Financial action task force (FATF) definitions are seriously flawed. The question of whether detecting TBML on the basis of statistical trade data is effective should be much more open to debate. Police investigations show that goods are shipped at their true value within the context of TBML.

Using outliers to identify and act on cases of TBML has often been propagated, but scarcely been used to actually show TBML. Real findings are needed.

Goods intended for TBML can also be paid for in cash. These cash payments are often out of character with the normal clientele. This should alert companies and compliance sections of banks alike.

The critique on the FATF definition opens the field for a more fitting definition. The description of actual TBML cases makes it possible to better understand this method of money laundering.

The purpose of this paper is to share research data from the Financial Intelligence sector on trade-based money laundering (TBML), as a way to better inform banking risk assessment and the submission of suspicious activity reports (SARs).

The research data formed part of a bigger project on TBML banking risk assessment for improving the detection of TBML activity. This paper analysed the data from an online survey carried out among the financial intelligence staff from financial intelligence units (FIUs) and some external financial intelligence agencies. The aim was to determine which areas of banking SARs needed to be improved or enhanced to support FIU investigations.

The research found that FIUs do use the data supplied to them, in particular the SARs. The research also found that more data would be appreciated from banks especially in relation to beneficial ownership information and politically exposed persons data. The findings highlighted that contact between banks and FIUs was limited and restricted to a couple of key individuals, whereas the increased requirement for intelligence and more data would suggest that this relationship needs to be expanded and strengthened.

The main limitation was the restricted scope of the survey (only focussed on TBML) and was broad in depth, and perhaps a local FIU survey would be useful to look at specific country recommendations. Similar research also needs to be conducted on other forms of ML activity. The research identified the need for more information on beneficial ownership information; however, other work needs to be done on how exactly banks can access this data.

The main outcome from the research was the need for SARs to contain more detailed information on beneficial ownership and politically exposed persons data. This needs to be incorporated into a specific risk assessment tool for TBML that considers not only the client but also relevant business partners and silent partners/shell companies used by the client. This research is part of a bigger research project that has developed a risk matrix tool for TBML and can be linked into this work.

The paper used original data collected by the researcher from 49 FIU and financial intelligence staff across the globe. The timely presentation of the results and the nature of the sample means that this is relevant and useful data to be presented to the banking sector.

As determined by the Financial Action Task Force, trade‐based money laundering (TBML) has become one of the three major money laundering methods used today. However, there has been very limited acknowledgment of the risk and counter‐measures against TBML until recently. This is particularly problematic with ever increasing trade volumes through transshipment and container shipping which is getting larger by the day. This paper aims to examine the role of TBML as a vehicle for terrorism financing and laundering proceeds of other criminal activity. It also examines the practice of transshipment, analyzes the challenges that this particular phenomenon poses to detection of TBML activity, and looks at possible alternative policy responses to mitigate additional money laundering risks.

This paper analyzes reports made by international organizations and government bodies, particularly, the US Government, dealing with various aspects of financial crime, import/export activity, and world trade statistics, in order to identify major challenges and possible solutions to the problem. Interviews were also conducted with the same goals.

Efforts to monitor and staunch the flow of illicit money through trade would be enhanced through more widespread coverage of customs cooperation and standardization of information sharing procedures between national customs agencies. Also, measures should be taken to make free trade areas more transparent to regulatory scrutiny.

This paper serves to expand the limited amount of scholarship on TBML and to suggest a policy approach towards detection of this kind of money laundering activity to policymakers.

This paper aims to provide unique empirical findings exploring the impact of the UK’s post-Brexit Economic Strategy to boost trade with developing countries on the UK banking sector’s ability to manage trade-based money laundering risks.

Exploratory research design that used structured literature review, followed by semi-structured interviews with key subject matter experts employed by large UK banks.

Both banks and law enforcement struggle to prioritise trade-based money laundering (TBML) intelligence discovery due to deficient skills, resources, technology and lack of strong regulatory stimulus. The regulated sector calls for the UK anti-money laundering (AML) reform that would better incentivise TBML deterrence, yet the Government underestimates the money laundering risks while trading with high-risk jurisdictions post-Brexit.

The findings are based on a small sample of six semi-structured interviews with difficult to access population of key subject matter experts. Despite the small sample, participants provided well-articulated and informed insights.

The UK’s post-Brexit Economic Strategy to boost trade with developing countries downplays the TBML risks it carries. The findings should alert UK banks, law enforcement and the Government who will collectively bear the responsibility to effectively manage TBML while enabling smooth trading.

The research provides unique perceptions of UK banks’ senior subject matter experts on managing TBML threats from opportunistic criminals.

This paper aims to explore in depth some of the main criminal elements involved in trade-based money laundering (TBML) and outlines the gaps in banking risk assessment as a result of this. The focus is on new and emerging risks due to criminal manipulation of the anti-money laundering (AML) risk assessment processes.

The paper uses secondary data to provide the current context in which TBML risk assessment is being carried out and how criminals have responded to this; it concludes the empirical section by surmising the emerging risks that AML risk assessment need to consider. The paper then introduces the basic components that future theoretical frameworks looking at banking AML risk assessment would need to consider. This includes a more in-depth understanding of how criminals are bypassing AML risk assessment so that countermeasures can be put in place and AML frameworks strengthened and updated.

The main findings are that sophisticated criminal processes exist that can be used to bypass and divert current banking risk assessment techniques. An overdependence on traditional customer due diligence and transaction monitoring can easily be thwarted, and banks need to develop a stronger AML assessment framework.

The research focused primarily on client documentation; however, another area of research would be needed to cover criminal manipulation of trade documents and other components of TBML transactions.

The implications from the research affect any financial organization undertaking AML risk analysis or compliance. It applies to the banking, insurance and auditing professions, as well as is of interest to academics working on TBML projects.

The social implications are that non-criminal clients within banks could be faced with tougher requirements for documentation and ID proof, which could reduce efficiency and, if not handled properly, even alienate further some sectors of society who are already struggling to access the main banking and financial services sectors.

The originality of this paper is the inclusion of criminal responses to TBML risk assessment and a review of flaws and gaps in AML risk assessment procedures. Dynamic risk assessment needs to be continuously updated and new emerging market risks appropriately addressed. This paper highlights some of the current and emerging AML risks for the banking and financial services sector.

This paper (written in August 2015) aims to discuss the regulatory approach to detecting and preventing trade-based money laundering (TBML) by using the example of Financial Crimes Enforcement Network (FinCEN) and its use of geographic targeting orders.

The paper uses both theoretical and empirical reports on TBML to explore whether increased regulation will ultimately achieve the ends it claims to offer.

The main findings from the analysis are that increased regulation has been found to have a negative impact on improving TBML detection. There is evidence that it causes an over-defensive response from banks that leads to a decrease in useful information to financial intelligence units.

The research topic is very new and an emerging topic; therefore, analysis papers and other academic writing on this topic are limited.

This paper has implications for both the regulatory and the banking/financial service sectors.

The originality of this paper is the deeper analysis of a specific TBML case, and the focus is on both the theoretical and empirical implications of the approach being used.