AdvancedCompliance & Risk · 4 of 8

Trade-Based Money Laundering Red Flags

Learn common indicators without treating an indicator as proof of crime.

Value can move through trade

Trade can be abused by misrepresenting price, quantity or quality, using fictitious shipments or routing transactions in ways that disguise value movement.

Document mismatches matter

Large unexplained differences between invoices, bills of lading, goods descriptions or market values can be important risk indicators.

Economic logic matters

A shipment that does not fit the customer’s business, uses an unnecessarily complex route, or has payment terms that make little commercial sense can deserve investigation.

Indicator is not verdict

FATF risk indicators are prompts for further review. A red flag does not by itself prove money laundering or fraud. Context and evidence matter.

Standards / source note: FATF/Egmont trade-based money-laundering guidance identifies patterns such as invoice/value discrepancies, unusual routes and transactions inconsistent with a customer’s normal business.
Remember thisA red flag means “look closer,” not “guilty.”
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Check 1

Does one TBML red flag prove criminal activity?

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