DON'T LOOK FOR TRADITIONAL TBML TYPOLOGIES IN THE PERIOD OF GLOBAL DISRUPTION

f you are a compliance officer conducting transaction monitoring for Trade-Based Money Laundering, current conditions mandate that you cease looking for the generally-accepted types of TBML methods and techniques, because the chaotic situation in the world's two major maritime transfer points means that laundrymen, always adapting to changed conditions on the ground, have changed the game in major ways.

First of all, as we have previously explained in our other articles analyzing the status of TBML in 2024, it is far easier to create what appears to be a legitimate response to the emergency situation with global routes, but in truth and in fact is a cleverly disguised laundering operation, complete with bogus costs or charges, or modified transport arrangements that have dropped in phantom, but credible, charges added on. In short, all the traditional shipping rules and guidelines have gone right out the window. Enter resourceful TBML laundrymen repeatedly and consistently pulling the financial wool over the eyes of watchful(?) compliance officers.

Therefore, discard your conventional thinking about the well-known TBML techniques, for we have gone past that now. During your analysis, take apart each financial component of current trade payment transactions, to find the ringers and posers, to cull out the Trade-Based Money Laundering from the legitimate payments for products and transport costs. Dig deep, gentlemen, and you will find the fictitious costs and charges in this brave new world of trade disruption being exploited by TBML laundrymen. Catch them if you can.