Saturday, February 17, 2024

SUSPECTED PRICE GOUGING IN RESPONSE TO INTERNATIONAL TRADE DISRUPTION ONLY HELPS TRADE-BASED MONEY LAUNDERERS SUCCEED


We note with concern that shipping costs, from East Asia to West Coast of the United States Ports of Entry have increased over 130% of late, and remind our readers that there are NO issues with decreased canal access, threats of attacks upon commercial vessels on that route, or any other of the trade disruptions we are experiencing in 2024. Is this simply because the increase in demand has spawned price gouging by the shipping companies? We also have reports that insurance costs have skyrocketed, especially War Risk, on all major shipping routes, even those that are obstacle- and trouble-free. is this simply another instance of greed (price gouging) taking over all aspects of the maritime industry?

The lack of uniformity in costs, free and charges, due in large part to the responses to the current problems importers experience in getting consumer and commodity products to their customary destinations and markets, only makes the job of TBML laundrymen easier, because compliance officers cannot rely upon established pricing norms, prior shipment cost averages, and other benchmarks that they typically use when monitoring transactions and payment information of their clients. With costs & charges, direct as well as indirect, in a state of flux, almost daily, there are no bases for comparison.

Compliance officers might therefore be well advised to look for other telltale sign of money laundering, misdeclaration, tax evasion, transfer pricing, shell companies, and those red flags which generally apply to financial crimes other than Trade-based Money Laundering. However you respond to the unfolding situation, be alert for any activity that appears to be inconsistent with your clients' prior conduct, is inconsistent with their relationship to their customers or third parties, or is in any way generating reasonable suspicions, requiring further ( and therefore deeper) inquiries. Catch them if you can.

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