Tipping the Scale in the Fight Against TBML

Jeffrey J. Pedecine, CAMS-FCI

While money launderers have long exploited the financial system and its various products to mask the origins of ill-gotten funds, the increased scrutiny around Trade Based Money Laundering (TBML) has only really escalated and come under fire in the past decade.

As TBML has emerged as both a critical financial and reputational risk to financial institutions globally and ultimately as an imminent threat to the safety of the general population, it is the intention of this paper to explore the controls required to successfully mitigate the TBML risks of doing business in the field of Trade and Supply Chain banking. While the thematic principals and controls of this paper can be applied to financial institutions of varying size, the scope of this document generally targets large and midsize banks operating with heavy volumes of international cross border trade.

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