MOVEMENT OF TIME-SENSITIVE ASIA-TO-EUROPE GOODS FROM TRADITIONAL MARITIME TRANSPORT INTO AIR CARGO, DUE TO RED SEA DANGERS, GIVES TBML OPERATORS AN ADDITIONAL CARD TO PLAY

According to industry observers, some companies that generally ship their Asia-produced consumer goods to the Member nations of the European Union, through the now-unavailable Suez Canal route, have abruptly switched to sending them via air cargo. Available statistics indicate a 63% increase in westbound air cargo traffic in January, regarding the types of goods which require timely receipt for distribution in retail markets, such as designer clothing, which must be on the shelves by specific dates on the calendar, to maximize sales. Prices to consumers are expected to increase accordingly, due to additional transport expenses incurred.

This information is significant for compliance officers in that international air transport of goods is completed in hours, a much shorter period than the days and weeks it takes for maritime transport from one continent to another. The window that compliance has to identify potential Trade-Based Money Laundering transactions is therefore extremely short, and multiple repetitions of the same TBML scheme can be completed, should the first one go through undetected.

Additionally, air cargo arrangements can be initiated and airborne in short order, and land before compliance even becomes aware of it. In short, a huge amount of new air cargo shipments might overwhelm the ability of bank compliance officers to properly review them. All this new air cargo traffic might facilitate expanded TBML operations. We trust that compliance departments are not only aware of the increased aviation shipping traffic, but that they have taken steps to monitor it, to insure that it is not being ignored. Remember that laundrymen using TBML tricks are flexible and reactive; any opening that might be occurring will find them there ahead of gatekeepers.