Trade-Based Money Laundering: Red Flags and Risks

Red Flags of Trade-Based Money Laundering

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Question

An automotive parts company in South America sends multiple $500,000 wire transfers per week to ABC Holdings Ltd. in Asia referencing payment for silk flower shipments. Research reveals Sunrise Holdings, Ltd is registered in the British Virgin Islands with no available ownership information.

What are two red flags that indicate how trade-based money laundering could be occurring in this instance? (Choose two.)

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Explanations

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A. B. C. D.

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Based on the information provided, there are two potential red flags that suggest trade-based money laundering (TBML) may be occurring in this instance:

  1. The transaction involves the use of front (or shell) companies: The use of front (or shell) companies is a common tactic used in TBML schemes. These entities are often created solely for the purpose of moving illicit funds through legitimate trade channels, and their ownership information may be hidden or difficult to obtain. In this case, the fact that Sunrise Holdings, Ltd is registered in the British Virgin Islands with no available ownership information is a red flag that suggests this entity may be a front (or shell) company used to facilitate illicit transactions.

  2. Significant discrepancies appear between the description of the commodity on the bill of lading and the invoice: Trade-based money laundering often involves misrepresenting the value, quantity, or nature of goods being shipped in order to facilitate illicit financial transactions. In this case, the fact that there are significant discrepancies between the description of the commodity on the bill of lading and the invoice raises suspicion that the automotive parts company and ABC Holdings Ltd. may be engaged in a TBML scheme. Specifically, the fact that they are referencing payment for silk flower shipments when the company is an automotive parts company suggests that the nature of the transactions may not be accurately represented, and may be a way to move illicit funds through trade channels.

Option B (The packaging is inconsistent with the commodity or shipping method) and Option D (The type of commodity being shipped appears inconsistent with the exporter or importer's regular business activities) are not necessarily relevant to the information provided in this scenario, and do not indicate specific red flags for TBML.