Everything You Need to Know About Trade Based Money Laundering
Are Definition, Process, Methods, Red flag indicators and statistics for Trade Based Money Laundering means everything?
Definition & Process
FATF defined trade-based money laundering (TBML) as the process of disguising the proceeds of crime and moving value through the use of trade transactions in an attempt to legitimize their illicit origins.
In practice, this can be achieved through the misrepresentation of the price, quantity or quality of imports or exports. Moreover, trade-based money laundering techniques vary in complexity and are frequently used in combination with other money laundering techniques to further obscure the money trail.
Money launderers can move money out of one country by simply using their illicit funds to purchase high-value products, and then exporting them at very low prices to a colluding foreign partner, who then sells them in the open market at their true value.
To give the transactions an air of legitimacy, the partners may use a financial institution for trade financing, which often entails letters of credit and other documentation.
Methods of Trade Based Money Laundering
TBML represents an important channel of criminal activity and, given the growth of world trade, an increasingly important money laundering and terrorist financing vulnerability.
Moreover, as the standards applied to other money laundering techniques become increasingly effective, the use of trade-based money laundering can be expected to become increasingly attractive. Trade-based money laundering involves using of the following techniques to disguise the illicit origin of money:
Over-invoicing and Under-invoicing:
Money laundering through the over- and under-invoicing of goods and services, which is one of the oldest methods of fraudulently transferring value across borders, remains a common practice today. The key element of this technique is the misrepresentation of the price of the good or service in order to transfer additional value between the importer and exporter.
• Over-invoicing: By invoicing the goods or service at a price above the fair market price, the seller is able to receive value from the buyer (i.e., the payment for the goods or service will be higher than the value that the buyer receives when it is sold on the open market).
• Under-invoicing: By invoicing the goods or service at a price below the fair market price, the seller is able to transfer value to the buyer (i.e., the payment for the goods or service is lower than the value that the buyer will receive when it is sold on the open market).
The over- and under-invoicing of exports and imports can have significant tax implications. An exporter who over-invoices the value of the goods that he ships may be able to significantly increase the value of the export tax credit (or valued-added tax (VAT) rebate) that he receives.
Similarly, an importer who is under-invoiced for the value of the goods that he receives may be able to significantly reduce the value of the import duties (or customs taxes) that he pays. Both of these cases illustrate the link between trade-based money laundering and abuse of the tax system.
Over-shipping or Short-shipping:
The difference in the invoiced quantity of goods and the quantity of goods that are shipped whereby the buyer or seller gains excess value based on the payment made.
Ghost-shipping:
Fictitious trades where a buyer and seller collude to prepare all the documentation indicating goods were sold, shipped and payments were made, but no goods were actually shipped.
Shell companies:
Shell companies are used to reduce the transparency of ownership in the transaction.
Multiple Invoicing:
Another technique used to launder funds involves issuing more than one invoice for the same international trade transaction. By invoicing the same good or service more than once, a money launderer or terrorist financier is able to justify multiple payments for the same shipment of goods or delivery of services.
Employing a number of different financial institutions to make these additional payments can further increase the level of complexity surrounding such transactions.
In addition, even if a case of multiple payments relating to the same shipment of goods or delivery of services is detected, there are a number of legitimate explanations for such situations including the amendment of payment terms, corrections to previous payment instructions or the payment of late fees.
Unlike over- and under-invoicing, it should be noted that there is no need for the exporter or importer to misrepresent the price of the good or service on the commercial invoice.
Falsely Described Goods and Services
In addition to manipulating export and import prices, a money launderer can misrepresent the quality, identity or type of a good or service. For example, an exporter may ship a relatively inexpensive good and falsely invoice it as a more expensive item or an entirely different item.
This creates a discrepancy between what appears on the shipping and customs documents and what is actually shipped. The use of false descriptions can also be used in the trade in services, such as financial advice, consulting services and market research. In practice, the fair market value of these services can present additional valuation difficulties.
Black market trades:
Commonly referred to as the Black Market Peso Exchange whereby a domestic transfer of funds is used to pay for goods by a foreign importer. Letters of credit are another vehicle for money laundering.
Letters of credit are a credit instrument issued by a bank that guarantees payments on behalf of its customer to a third party when certain conditions are met. Letters of credit are commonly used to finance export because exporters want assurance that the ultimate buyer of its goods will make payment and this is given by the buyer’s purchase of a bank letter of credit.
The letter of credit is then forwarded to a correspondent bank in the jurisdiction in which the payment is to be made. The letter of credit is drawn on when the goods are loaded for shipping, received at the importation point, clear customs and are delivered.
Letters of credit can be used to facilitate money laundering by transferring money from a country with lax exchange controls, thus assisting in creating the illusion that an import transaction is involved.
Moreover, letters of credit can also serve as a façade when laundering money through the manipulation of import and export prices. Another method of using letters of credits illicitly is in conjunction with wire transfers to bolster the legitimate appearance of non- existent trade transactions.
Trade Based Money Laundering "Red Flag" Indicators
Although Trade Based Money Laundering is extremely difficult to monitor, track and identify, there are common situational or behavioral indicators, or “Red Flags”, that Banks should be aware of:
Customers→ Is the nature of each trade consistent with the customer's business?
Countries→ Are the buyer, seller, vessel or bank involved in the trade on a sanctions list?
Transactions and Goods→ Is there potential for tax avoidance or money laundering?
Documentation and Products→ Are there complete, accurate and precise documentation for each trade?
Red flags may be present in every step of the Trade finance process and should be promptly examined. Although it is not necessarily an indicator of criminal activity, the presence of a Red flag requires thorough investigation, in order to properly determine if unlawful acts were committed.
1. The transaction involves the receipt of cash (or by other payment methods) from third party entities that have no apparent connection with the transaction or which involve front or shell companies or wire instructions/ payment from parties which were not identified in the original letter of credit or other documentation.
The transactions that involve payments for goods through cheques, bank drafts or money orders not drawn on the account of the entity that purchased the items also need further verification.
2. A client uses unusual or suspicious identification documents that cannot be readily verified.
3. A business is reluctant, when establishing a new trade relationship, to provide complete information about the nature and purpose of its business, anticipated trade activity, prior banking relationship, the names of its officers and directors or information on its business location.
4. A client's home or business telephone is disconnected.
5. The client’s background differs from that which would be expected on the basis of his or her business activities.
6. A party to a transaction is a shell company.
7. Transacting businesses share the same address, provide only registered agent’s address or have other address inconsistencies.
8. Upon request, the customer refuses to identify or fails to indicate any legitimate source for his or her funds and other assets.
9. A client who significantly deviates from their historical pattern of trade activity (i.e. in terms of value, frequency or merchandise).
10. The customer wishes to engage in transactions that lack business sense or apparent investment strategy or are inconsistent with the customer’s stated business strategy (e.g. a steel company that starts dealing in paper products or an information technology company that starts dealing in bulk pharmaceuticals).
11. Customers involved in potentially higher-risk activities, including activities that may be subject to export/import restrictions(e.g. equipment for military or police organizations of foreign governments, weapons, ammunition, chemical mixtures, classified defense articles, sensitive technical data, nuclear materials, precious gems or certain natural resources such as metals, ore and crude oil).
12. The customer (or a person publicly associated with the customer) has a questionable background or is the subject of news reports indicating possible criminal, civil or regulatory violations.
13. The customer exhibits a lack of concern regarding risks, commissions or other transaction costs.
14. The customer has little experience in the product in which they are dealing or does not seem to appreciate the risks associated.
15. The customer requests that a transaction be processed in such a manner to avoid the firm's normal documentation requirements.
16. Excessive insistence of the customer to complete the transaction quickly.
17. Transactions which are between parties controlled by the same business entity.
18. Use of letter of credit to move money between those countries, where such trade would not normally occur and or is not consistent with customer's usual business activity. A letter of credit is generally resorted to so as to accord more legitimacy to the transaction in order to conceal the real facts.
19. The method of payment requested by the client appears inconsistent with the risk characteristics of the transaction. For example receipt of an advance payment, for a shipment, from a new seller in a high- risk jurisdiction.
20. Shipment locations of the goods, shipping terms or descriptions of the goods are inconsistent with letter of credit. This may include changes in shipment locations to high risk countries or changes in the quality of the goods shipped.
21. Customers are conducting business in higher-risk jurisdictions or geographic locations, particularly when shipping items through higher- risk or non- cooperative countries as defined in the AML Risk Drivers. However, this attribute in isolation would not necessarily deem a transaction as high risk.
22. Significantly amended letters of credit without reasonable justification or changes to the beneficiary or location of payment. Any changes in the names of parties also should prompt additional UN/OFAC/EU review.
23. Unusual deposits i.e. use of cash or negotiable instruments(such as traveller's cheques, cashier's cheques and money orders) in round denominations(to keep below reporting threshold limit) to fund bank accounts and pay for goods and services.
The negotiable instruments may sequentially numbered or purchased at multiple locations and may frequently lack payee information. Further, cash payments for high –value orders are also indication of TBML activity.
24. Inward remittances in multiple accounts and payments made from multiple accounts for trade transaction of same business entity are indicators for TBML. In this regard the study of foreign exchange remittances may help detect the offence.
25. In the case of merchant’s trade, the trade finance mechanism should be in place for both export leg as well as import leg of transaction. If the trade finance mechanism, for example, Letters of Credit have been provided for only the import leg of the transaction and not for export leg, it also indicates the possibility of TBML.
26. Goods or services purchased by the business do not match the customer's stated line of business.
27. The size of shipment appears inconsistent with the scale of the exporter or importer's regular business activities.
28. The transaction involves the receipt of cash (or other payments) from third party entities that have no apparent connection with transaction.
29. Transport documents do not match letter of credit documents and evidence an over-shipment or under shipment not covered by the letter of credit agreement.
30. Significant discrepancies appear between the descriptions of the goods on the bill of lading (or invoice) and the actual goods shipped.
31. Sudden and unexplained increases in a customer's normal trade transactions.
32. Obvious misrepresentation of quantity or type of goods imported or exported.
33. Obvious over or under pricing of goods and services (as per information received from our regulators, we are not expected to be pricing experts on the many products that could be involved in trade transactions.
However, staff completing trade transactions should generally know that over or under pricing can be an indicator of money laundering and or fraud and any instances that come to their attention should be investigated and if suspicious reported).
34. Transaction structure appears unnecessarily complex and designed to obscure the true nature of the transaction.
35. The method of payment appears inconsistent with the risk characteristics of the transaction. For example, the use of an advance payment for a shipment from a new supplier in a high risk country.
36. The shipment does not make economic sense. For example, the use of a forty foot container to transport a small amount of relatively low value goods.
37. Regarding nonprofit or charitable organizations, financial transactions occur for which there appears to be no logical economic purpose or in which there appears to be no link between the stated activity of the organization and the other parties in the transaction.
38. Additionally the shipment of any high value items (such as electronics, autos, auto parts, gems and precious metals) in conjunction with other indicators may be reason for further review.
39. Other in consistencies to be considered;
(a)Routine installation, training or maintenance services are declined by customer.
(b)Delivery dates are vague or deliveries are planned for out of the way destinations.
(c) A freight forwarding firm is listed as the product's final destination.
(d) Packaging is consistent with the stated method of shipment or destination.
40. The transaction involves the use of repeatedly amended or frequently extended letters of credit without reasonable justification or that includes changes in regard to the beneficiary or location of payment without any apparent reason.
41. "Unnecessarily complex" and confusing transaction structures. These structures potentially aim to obscure a transaction’s true purpose and nature.
42. A payment method that does not match the risk characteristics of the transaction.
43. Requests by exporters to take back and replace trade and shipping documents, notably if the new documents provided have been altered or issued by a different entity.
44. Abnormal markings on monetary instruments.
45. Modifications to third party documents, such as customs forms.
Statistics of TBML:
Transnational crime is worth up to US$2.2tn each year and much of it is facilitated by trade mis-invoicing and other forms of trade-based money laundering (TBML).Trade-based money laundering, typically through trade mis-invoicing, has become the main vehicle for illicit financial flows (IFFs) around the world. This form of money laundering involves deliberately misreporting the value of a commercial transaction on an invoice submitted to customs.
Global Financial Integrity (GFI), the non-profit research and advisory organization focused on illicit financial flows studies, estimates that 87% of illicit financial flows (IFFs) are due to fraudulent trade mis-invoicing, which results in a loss of billions in revenues, especially in developing nations.
The Economist calls it, "the weakest link in the fight against dirty money". Latin America and the Caribbean is a focal point for inflows and outflows of this particular type of financial crime.
Reference:
1. APG Typology Report on Trade Based Money Laundering, July 2012
2. FATF Report on Money Laundering vulnerabilities of free Trade zones (2010)
3. Wolfsberg Trade Finance Principles (January 2009)
Definition & Process
FATF defined trade-based money laundering (TBML) as the process of disguising the proceeds of crime and moving value through the use of trade transactions in an attempt to legitimize their illicit origins.
In practice, this can be achieved through the misrepresentation of the price, quantity or quality of imports or exports. Moreover, trade-based money laundering techniques vary in complexity and are frequently used in combination with other money laundering techniques to further obscure the money trail.
Money launderers can move money out of one country by simply using their illicit funds to purchase high-value products, and then exporting them at very low prices to a colluding foreign partner, who then sells them in the open market at their true value.
To give the transactions an air of legitimacy, the partners may use a financial institution for trade financing, which often entails letters of credit and other documentation.
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| Everything You Need to Know About Trade Based Money Laundering |
Methods of Trade Based Money Laundering
TBML represents an important channel of criminal activity and, given the growth of world trade, an increasingly important money laundering and terrorist financing vulnerability.
Moreover, as the standards applied to other money laundering techniques become increasingly effective, the use of trade-based money laundering can be expected to become increasingly attractive. Trade-based money laundering involves using of the following techniques to disguise the illicit origin of money:
Over-invoicing and Under-invoicing:
Money laundering through the over- and under-invoicing of goods and services, which is one of the oldest methods of fraudulently transferring value across borders, remains a common practice today. The key element of this technique is the misrepresentation of the price of the good or service in order to transfer additional value between the importer and exporter.
• Over-invoicing: By invoicing the goods or service at a price above the fair market price, the seller is able to receive value from the buyer (i.e., the payment for the goods or service will be higher than the value that the buyer receives when it is sold on the open market).
• Under-invoicing: By invoicing the goods or service at a price below the fair market price, the seller is able to transfer value to the buyer (i.e., the payment for the goods or service is lower than the value that the buyer will receive when it is sold on the open market).
The over- and under-invoicing of exports and imports can have significant tax implications. An exporter who over-invoices the value of the goods that he ships may be able to significantly increase the value of the export tax credit (or valued-added tax (VAT) rebate) that he receives.
Similarly, an importer who is under-invoiced for the value of the goods that he receives may be able to significantly reduce the value of the import duties (or customs taxes) that he pays. Both of these cases illustrate the link between trade-based money laundering and abuse of the tax system.
Over-shipping or Short-shipping:
The difference in the invoiced quantity of goods and the quantity of goods that are shipped whereby the buyer or seller gains excess value based on the payment made.
Ghost-shipping:
Fictitious trades where a buyer and seller collude to prepare all the documentation indicating goods were sold, shipped and payments were made, but no goods were actually shipped.
Shell companies:
Shell companies are used to reduce the transparency of ownership in the transaction.
Multiple Invoicing:
Another technique used to launder funds involves issuing more than one invoice for the same international trade transaction. By invoicing the same good or service more than once, a money launderer or terrorist financier is able to justify multiple payments for the same shipment of goods or delivery of services.
Employing a number of different financial institutions to make these additional payments can further increase the level of complexity surrounding such transactions.
In addition, even if a case of multiple payments relating to the same shipment of goods or delivery of services is detected, there are a number of legitimate explanations for such situations including the amendment of payment terms, corrections to previous payment instructions or the payment of late fees.
Unlike over- and under-invoicing, it should be noted that there is no need for the exporter or importer to misrepresent the price of the good or service on the commercial invoice.
Falsely Described Goods and Services
In addition to manipulating export and import prices, a money launderer can misrepresent the quality, identity or type of a good or service. For example, an exporter may ship a relatively inexpensive good and falsely invoice it as a more expensive item or an entirely different item.
This creates a discrepancy between what appears on the shipping and customs documents and what is actually shipped. The use of false descriptions can also be used in the trade in services, such as financial advice, consulting services and market research. In practice, the fair market value of these services can present additional valuation difficulties.
Black market trades:
Commonly referred to as the Black Market Peso Exchange whereby a domestic transfer of funds is used to pay for goods by a foreign importer. Letters of credit are another vehicle for money laundering.
Letters of credit are a credit instrument issued by a bank that guarantees payments on behalf of its customer to a third party when certain conditions are met. Letters of credit are commonly used to finance export because exporters want assurance that the ultimate buyer of its goods will make payment and this is given by the buyer’s purchase of a bank letter of credit.
The letter of credit is then forwarded to a correspondent bank in the jurisdiction in which the payment is to be made. The letter of credit is drawn on when the goods are loaded for shipping, received at the importation point, clear customs and are delivered.
Letters of credit can be used to facilitate money laundering by transferring money from a country with lax exchange controls, thus assisting in creating the illusion that an import transaction is involved.
Moreover, letters of credit can also serve as a façade when laundering money through the manipulation of import and export prices. Another method of using letters of credits illicitly is in conjunction with wire transfers to bolster the legitimate appearance of non- existent trade transactions.
Trade Based Money Laundering "Red Flag" Indicators
Although Trade Based Money Laundering is extremely difficult to monitor, track and identify, there are common situational or behavioral indicators, or “Red Flags”, that Banks should be aware of:
Customers→ Is the nature of each trade consistent with the customer's business?
Countries→ Are the buyer, seller, vessel or bank involved in the trade on a sanctions list?
Transactions and Goods→ Is there potential for tax avoidance or money laundering?
Documentation and Products→ Are there complete, accurate and precise documentation for each trade?
Red flags may be present in every step of the Trade finance process and should be promptly examined. Although it is not necessarily an indicator of criminal activity, the presence of a Red flag requires thorough investigation, in order to properly determine if unlawful acts were committed.
1. The transaction involves the receipt of cash (or by other payment methods) from third party entities that have no apparent connection with the transaction or which involve front or shell companies or wire instructions/ payment from parties which were not identified in the original letter of credit or other documentation.
The transactions that involve payments for goods through cheques, bank drafts or money orders not drawn on the account of the entity that purchased the items also need further verification.
2. A client uses unusual or suspicious identification documents that cannot be readily verified.
3. A business is reluctant, when establishing a new trade relationship, to provide complete information about the nature and purpose of its business, anticipated trade activity, prior banking relationship, the names of its officers and directors or information on its business location.
4. A client's home or business telephone is disconnected.
5. The client’s background differs from that which would be expected on the basis of his or her business activities.
6. A party to a transaction is a shell company.
7. Transacting businesses share the same address, provide only registered agent’s address or have other address inconsistencies.
8. Upon request, the customer refuses to identify or fails to indicate any legitimate source for his or her funds and other assets.
9. A client who significantly deviates from their historical pattern of trade activity (i.e. in terms of value, frequency or merchandise).
10. The customer wishes to engage in transactions that lack business sense or apparent investment strategy or are inconsistent with the customer’s stated business strategy (e.g. a steel company that starts dealing in paper products or an information technology company that starts dealing in bulk pharmaceuticals).
11. Customers involved in potentially higher-risk activities, including activities that may be subject to export/import restrictions(e.g. equipment for military or police organizations of foreign governments, weapons, ammunition, chemical mixtures, classified defense articles, sensitive technical data, nuclear materials, precious gems or certain natural resources such as metals, ore and crude oil).
12. The customer (or a person publicly associated with the customer) has a questionable background or is the subject of news reports indicating possible criminal, civil or regulatory violations.
13. The customer exhibits a lack of concern regarding risks, commissions or other transaction costs.
14. The customer has little experience in the product in which they are dealing or does not seem to appreciate the risks associated.
15. The customer requests that a transaction be processed in such a manner to avoid the firm's normal documentation requirements.
16. Excessive insistence of the customer to complete the transaction quickly.
17. Transactions which are between parties controlled by the same business entity.
18. Use of letter of credit to move money between those countries, where such trade would not normally occur and or is not consistent with customer's usual business activity. A letter of credit is generally resorted to so as to accord more legitimacy to the transaction in order to conceal the real facts.
19. The method of payment requested by the client appears inconsistent with the risk characteristics of the transaction. For example receipt of an advance payment, for a shipment, from a new seller in a high- risk jurisdiction.
20. Shipment locations of the goods, shipping terms or descriptions of the goods are inconsistent with letter of credit. This may include changes in shipment locations to high risk countries or changes in the quality of the goods shipped.
21. Customers are conducting business in higher-risk jurisdictions or geographic locations, particularly when shipping items through higher- risk or non- cooperative countries as defined in the AML Risk Drivers. However, this attribute in isolation would not necessarily deem a transaction as high risk.
22. Significantly amended letters of credit without reasonable justification or changes to the beneficiary or location of payment. Any changes in the names of parties also should prompt additional UN/OFAC/EU review.
23. Unusual deposits i.e. use of cash or negotiable instruments(such as traveller's cheques, cashier's cheques and money orders) in round denominations(to keep below reporting threshold limit) to fund bank accounts and pay for goods and services.
The negotiable instruments may sequentially numbered or purchased at multiple locations and may frequently lack payee information. Further, cash payments for high –value orders are also indication of TBML activity.
24. Inward remittances in multiple accounts and payments made from multiple accounts for trade transaction of same business entity are indicators for TBML. In this regard the study of foreign exchange remittances may help detect the offence.
25. In the case of merchant’s trade, the trade finance mechanism should be in place for both export leg as well as import leg of transaction. If the trade finance mechanism, for example, Letters of Credit have been provided for only the import leg of the transaction and not for export leg, it also indicates the possibility of TBML.
26. Goods or services purchased by the business do not match the customer's stated line of business.
27. The size of shipment appears inconsistent with the scale of the exporter or importer's regular business activities.
28. The transaction involves the receipt of cash (or other payments) from third party entities that have no apparent connection with transaction.
29. Transport documents do not match letter of credit documents and evidence an over-shipment or under shipment not covered by the letter of credit agreement.
30. Significant discrepancies appear between the descriptions of the goods on the bill of lading (or invoice) and the actual goods shipped.
31. Sudden and unexplained increases in a customer's normal trade transactions.
32. Obvious misrepresentation of quantity or type of goods imported or exported.
33. Obvious over or under pricing of goods and services (as per information received from our regulators, we are not expected to be pricing experts on the many products that could be involved in trade transactions.
However, staff completing trade transactions should generally know that over or under pricing can be an indicator of money laundering and or fraud and any instances that come to their attention should be investigated and if suspicious reported).
34. Transaction structure appears unnecessarily complex and designed to obscure the true nature of the transaction.
35. The method of payment appears inconsistent with the risk characteristics of the transaction. For example, the use of an advance payment for a shipment from a new supplier in a high risk country.
36. The shipment does not make economic sense. For example, the use of a forty foot container to transport a small amount of relatively low value goods.
37. Regarding nonprofit or charitable organizations, financial transactions occur for which there appears to be no logical economic purpose or in which there appears to be no link between the stated activity of the organization and the other parties in the transaction.
38. Additionally the shipment of any high value items (such as electronics, autos, auto parts, gems and precious metals) in conjunction with other indicators may be reason for further review.
39. Other in consistencies to be considered;
(a)Routine installation, training or maintenance services are declined by customer.
(b)Delivery dates are vague or deliveries are planned for out of the way destinations.
(c) A freight forwarding firm is listed as the product's final destination.
(d) Packaging is consistent with the stated method of shipment or destination.
40. The transaction involves the use of repeatedly amended or frequently extended letters of credit without reasonable justification or that includes changes in regard to the beneficiary or location of payment without any apparent reason.
41. "Unnecessarily complex" and confusing transaction structures. These structures potentially aim to obscure a transaction’s true purpose and nature.
42. A payment method that does not match the risk characteristics of the transaction.
43. Requests by exporters to take back and replace trade and shipping documents, notably if the new documents provided have been altered or issued by a different entity.
44. Abnormal markings on monetary instruments.
45. Modifications to third party documents, such as customs forms.
Statistics of TBML:
Transnational crime is worth up to US$2.2tn each year and much of it is facilitated by trade mis-invoicing and other forms of trade-based money laundering (TBML).Trade-based money laundering, typically through trade mis-invoicing, has become the main vehicle for illicit financial flows (IFFs) around the world. This form of money laundering involves deliberately misreporting the value of a commercial transaction on an invoice submitted to customs.
Global Financial Integrity (GFI), the non-profit research and advisory organization focused on illicit financial flows studies, estimates that 87% of illicit financial flows (IFFs) are due to fraudulent trade mis-invoicing, which results in a loss of billions in revenues, especially in developing nations.
The Economist calls it, "the weakest link in the fight against dirty money". Latin America and the Caribbean is a focal point for inflows and outflows of this particular type of financial crime.
Reference:
1. APG Typology Report on Trade Based Money Laundering, July 2012
2. FATF Report on Money Laundering vulnerabilities of free Trade zones (2010)
3. Wolfsberg Trade Finance Principles (January 2009)
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