The Financial Action Task Force (FATF), an independent inter-governmental body, issued a report in 2013 outlining the vulnerabilities of legal professionals to money laundering and terrorist financing. 206 0 obj <>/Filter/FlateDecode/ID[<3A517144F93DEA4DA33124A65A09939C><9E1B8A634519BE41B78E2E48C3341261>]/Index[182 61]/Info 181 0 R/Length 115/Prev 109055/Root 183 0 R/Size 243/Type/XRef/W[1 3 1]>>stream For bank compliance officers, the situation is made more difficult due to one of the basic tenets of trade finance: “Banks deal with documents and not with goods, services or performance to which the documents relate.”1. h��[i�$E��+�4���C!=��,�� 准����@�������3������*蹤��gx�������Z�y�v��|(��v��[ߥXw��|,^2��w=H�����.%i��m'�PC 242 0 obj <>stream Merchants Acquired by A Bank For Credit Card Or Charge Card Transactions The Financial Action Task Force (FATF), the Paris-based global body of 36 governments which co-ordinates efforts on AML and counter–terrorist financing (CTF), notes in its current version of Best Practices on Trade-Based Money Laundering that this method of laundering h�bbd```b``6 �u ��D���G�H� ���V�&���X���"Yz��0�D���"���@���� 6�QDn���uw00�v © 2020, O’Reilly Media, Inc. All trademarks and registered trademarks appearing on oreilly.com are the property of their respective owners. Chapter 10 Red-Flag Indicators. 182 0 obj <> endobj As far as we know, they do not incorporate all the fields involved in a solid trade-based monitoring system. %PDF-1.5 %���� %PDF-1.6 %���� I also believe that financial institutions involved with financing transactions will face increasing pressure to assume a more proactive role in scrutinizing trade. h�b```����@��(�����as:�&��0��� +�������H�� 1(f`e�g�����C�A���_�ȱ_cN����P��{pz��e�� Hector X. Colon, the head of the U.S. TTU, acknowledges the debate and the difficulty and appeals for help: “TBML presents probably one of the most complex and dynamic forms of illicit money movement which undermines legitimate business and commerce. 59 0 obj <> endobj 84 0 obj <>/Filter/FlateDecode/ID[<988202D36C8F4BCD95F5971518E3F521><60D20CF4B2ED4FE09D1A8E43B9442990>]/Index[59 51]/Info 58 0 R/Length 118/Prev 150821/Root 60 0 R/Size 110/Type/XRef/W[1 3 1]>>stream Trade finance has emerged as priority concern for anti-money-laundering enforcers and compliance officials are taking a fresh look at the channel for risk factors as regulatory risk increases. These limitations define the degree of scrutiny and understanding a financial institution can bring to the identification of suspicious activity.2 Yet despite these self-imposed parameters, compliance officers might well have occasion to suspect unusual or suspicious activity. Trade Finance Activities — Overview FFIEC BSA/AML Examination Manual 267 2/27/2015.V2 Trade Finance Activities — Overview Objective. Some of the best originate from the ... Take O’Reilly online learning with you and learn anywhere, anytime on your phone and tablet. The FATF provides financial institutions with a list of trade finance AML red flags to consider when managing cross-border transactions; these include: Significant discrepancies between invoices and the description of goods on official documents. The new mentioned methodology will gather and tie-in all of the necessary key fields in trade. h�b```�nV.UAd`��0p�`Rhx,���)�!��ww��(y�t��ڒj��tx~�߶eL.����V�4͵�k``�� $4@$��@2x���iq ���10�W�dbf����r�����!�����fL�����`��a`4Z�pz�w~.&�iP��30�9iF��n�,��d)��� 30y퇈2 �9� endstream endobj 60 0 obj <>/Metadata 17 0 R/Pages 57 0 R/StructTreeRoot 54 0 R/Type/Catalog>> endobj 61 0 obj <>/Font<>/ProcSet[/PDF/Text]>>/Rotate 0/StructParents 0/Type/Page>> endobj 62 0 obj <>stream Exercise your consumer rights by contacting us at donotsell@oreilly.com. Fortunately, a number of concerned organizations have issued red-flag indicators or warning signs that could be indicative of TBML. Shipments with unusual traffic of goods handled by a particular importer or exporter. 0 �^��n׫db��&�Үw��;�K>Jk�. Sync all your devices and never lose your place. So, by demand, and in a short time you can detect a trade-based AML red flag and ultimately avoid the need to retrieve the paper documents. endstream endobj startxref Assess the adequacy of the bank’s systems to manage the risks associated with trade finance activities, and management’s ability to implement effective due diligence, monitoring, and reporting systems. TBML can be complex, confusing, and often hiding in plain sight. %%EOF Get Trade-Based Money Laundering now with O’Reilly online learning. Trade finance Six AML Red Flags By Bachir El Nakib (CAMS), Senior Consultant, Compliance Alert (LLC). It is important that compliance officers report suspicious activity that could help law enforcement identify and investigate TBML.”3. h�bbd```b``f��@$���fo�� �,Ϊf���b���d��`���`�{ R��n���$c�.��#��P�֫$�ߞ��t�+X��q������ �� (AML) policies and procedures to take account of this growing threat. Terms of service • Privacy policy • Editorial independence, Get unlimited access to books, videos, and. Potential Red Flags ... flag of vessel, flag history and name history (to check whether it is related to any country in the list of sanctioned countries); ... AML/CFT CONTROLS IN TRADE FINANCE AND CORRESPONDENT BANKING MONETARY AUTHORITY OF SINGAPORE 8 (b) Export (Inward) L/Cs Red flags TBML can be complex, confusing, and often hiding in plain sight. The report identifies 42 'Red Flag Indicators' or warning signs of money laundering and terrorist financing. �*�AA�g`:� � �w endstream endobj startxref 0 %%EOF 109 0 obj <>stream H^�jff`� d ���H3206 )v��_�\F9� #� According to the Wolfsberg Group, an association of global banks that promote AML/CFT standards, banks do not get involved with the physical goods, nor do they have the capability to do so. O’Reilly members experience live online training, plus books, videos, and digital content from 200+ publishers. endstream endobj 183 0 obj <.