Trade is a ready-made vehicle for dirty money. A basic technique used in trade for laundering money is misinvoicing. This is done by undervaluing imports or overvaluing exports to bring money into a country and the reverse to get money out). The CA Certificate of Completion in Trade-Based Money Laundering & Terrorist Financing (TBML) provides you with an opportunity to look at the AML and CTF models used to address the risks within the international trade environment. The course will also investigate some of the practical issues faced, where breaching money laundering requirements can cost hundreds of millions of dollars.

Case studies will be used during the session to provide practical hands on experience in developing Trade Based Money Laundering and Terrorist Financing prevention and detection practices.                   






This Trade Based AML/CFT Training is especially relevant for:

Client Facing Commercial Bankers, Trade & Commodity Finance Specialists, Customer Support staff, Risk Management analysts, and      AML Compliance Professionals who are keen to enhance their existing expertise by learning about another risk discipline, Practitioners within the international trade environment who wish to certify their knowledge, Operational staff working within international trade finance who wish to enhance their AML knowledge, Compliance Assuarnce Professionals who want to develop a deeper understanding of the risks they are monitoring, and anyone with an interest in the subject matter.



COURSE OBJECTIVES:               

At the end of the training, participants will have enhanced their awareness of AML/CFT issues related to trade and be able to:

  • Identify key TBML Red Flags;
  • Assess the AML risk profile of proposed trade transactions;
  • Advise clients regarding risks with respect to trade and cross-border financial crime;
  • Identify and mitigate abuse of Free Trade Zones and other offshore structures in trade transactions;
  • Spot AML Red Flags in a SWIFT MT 700;
  • Advise senior (risk) management regarding TBML matters






















Using presentations, group assignments and case study analyses the following TBML topics are addressed; essential concepts of Anti-Money Laundering and Terrorist Financing, you will cover the following learning areas:

The Fundamentals of TBML, Risk Management Variable Physical Goods. Variable Pricing of Goods, BMPE, Terrorist Resourcing, Proliferation Finance, Correspondent Banking, CDD, Basic Principles and Techniques, Typologies and AML/CFT Red Flags, Investigation Tools, such as Trade Data Analysis, Practical examples such as Black Market Peson Exchange Scheme, SWIFT MT 700 messaging and Red Flags.

Course Details

What is Trade Based Money Laundering & Terrorist Financing?

  • The international dimension of Trade Based Money Laundering and Terrorist Financing
  • What is the Government and Regulatory expectation?
  • Examples of Trade Based Money Laundering and Terrorist Financing and good practice/poor practice
  • Where is there guidance available to assist?
  • What are the challenges to preventing, detecting and investigating Trade Based Money Laundering and errorist Financing?


  • Trade Based Money Laundering & Terrorist Financing – a ‘risk assessment’ of products, geography, customers, segments
  • The role of Due Diligence in the TBML/TF process – who is the customer, KYCC, connected parties
  • Consideration of Money Laundering/Trade Finance in product development
  • Relationship of Trade Based Money Laundering and Terrorist Financing with Fraud

Detection and Investigation

  • Monitoring – red flags, “eye balling” of documents, automation (pre/post transaction)
  • Recording and Management of ‘suspicious activity’
  • Evidence gathering
  • Internal Investigations
  • Hotlines and whistle-blowing
  • Specific Case study

Policies and Procedures (systems and controls)

  • Roles and Responsibilities
  • Training and Awareness
  • Assurance/Governance 

After attending this course, attendees will be able to:

  • Understand the International threats related to Trade Based Money Laundering and Terrorist Financing
  • Understand Government and Regulatory expectations in relation to Trade Based Money Laundering and Terrorist Financing
  • Identify and conduct a risk assessment related to Trade Based Money Laundering and Terrorist Financing
  • Identify practical prevention and detection techniques to Trade Based Money Laundering and Terrorist Financing
  • Consider and apply appropriate actions when Trade Based Money Laundering and Terrorist Financing does occur
  • Consider the appropriate policies, procedures (systems and controls) applicable to their organisation.

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