CAMP by Risk Academy · Certified Anti Money Laundering Professional

Trade-Based Money Laundering (TBML) Online Course

Trade-based money laundering (TBML) is the movement of illicit value through trade transactions, most often by misstating the price, quantity or description of goods. An online course on it should cover how trade finance works, the main TBML techniques and the red flags in trade documents. In CAMP by Risk Academy, TBML is the largest module: 16 of the course's 68 lessons.

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What trade-based money laundering is

Trade moves enormous value across borders against documents: invoices, bills of lading, letters of credit. TBML exploits the gap between what those documents say and what was really shipped. If an exporter invoices goods at twice their worth, the importer's payment moves the excess abroad under cover of an ordinary sale.

It is hard to detect because the bank financing the trade sees paperwork, not cargo, and because pricing legitimately varies.

The main TBML techniques

Over-invoicing
Goods are invoiced above their real value, moving value from the importer to the exporter.
Under-invoicing
Goods are invoiced below their real value, moving value from the exporter to the importer.
Multiple invoicing
The same shipment is invoiced more than once to justify several payments.
Over- and under-shipment
The quantity shipped differs from the quantity invoiced.
Phantom shipment
Documents are produced for goods that were never shipped at all.
False description of goods
The quality or type of goods is misstated, for example low-grade goods described as high-grade.

These are often combined with shell companies and layered payments through third countries.

TBML red flags

  • Unit prices well above or below the market rate for the goods described.
  • Quantities or descriptions that differ between the invoice, the bill of lading and the packing list.
  • Goods that do not fit the customer's line of business.
  • A counterparty with no visible trading history or online presence.
  • Payment from or to a third party unconnected with the trade.
  • Shipping routes that make no commercial sense, or transhipment through high-risk jurisdictions.
  • Repeatedly amended letters of credit, or documents presented late.

The typology and red flag reference lists the monitoring rules built on these, and the case study examples include a worked TBML case on under-invoiced exports.

What CAMP's TBML module teaches

The Trade-Based Money Laundering module of CAMP has 16 lessons, more than any other module in the course:

  1. Understanding the Trade Finance
  2. Understanding Letter of Credit
  3. Understanding International Trade
  4. TBML Techniques Invoice Manipulation
  5. Mechanism of TBML
  6. Introduction to TBML
  7. Shipment Process
  8. Role of Financial Institutes
  9. Example of Crime in Trade
  10. Common TBML Techniques
  11. Business sectors and the Risk Associated with them
  12. Broad and Senior management Over site
  13. Understanding Missing Trader Fraud
  14. Red Flags of TBML
  15. Gold Laundering
  16. Diamond Trade

TBML alerts and cases also appear in the CAMP AML Investigation Simulator, where you investigate them and write them up for grading. The SAR narrative writing guide has a section on writing up TBML specifically.

A TBML-only course, or TBML within an AML certification?

Riskpro Learning offers both. The Certified Trade Based Money Laundering Expert is a short, standalone programme for people who need TBML on its own. CAMP is the fuller AML/CFT certification: it teaches TBML as one module among ten and tests it in the simulator alongside every other typology. Choose the first if TBML is the only gap; choose CAMP if you are preparing for an AML analyst or investigator role.

Frequently Asked Questions

What is trade-based money laundering?
Trade-based money laundering (TBML) is the process of disguising criminal proceeds and moving value through trade transactions. It typically works by misrepresenting the price, quantity or quality of goods in trade documents, so that a payment which looks like settlement for an ordinary sale in fact transfers illicit value across borders.
What are the common TBML techniques?
The common techniques are over-invoicing, under-invoicing, multiple invoicing of the same shipment, over- and under-shipment, phantom shipments where no goods move at all, and false description of the goods. They are often combined with shell companies and payments routed through third countries.
What are the red flags of trade-based money laundering?
Red flags include unit prices far from market rates, mismatches between the invoice, bill of lading and packing list, goods inconsistent with the customer's business, counterparties with no trading history, payments involving unrelated third parties, commercially illogical shipping routes and repeatedly amended letters of credit.
Does CAMP include trade-based money laundering?
Yes. Trade-Based Money Laundering is the largest module in CAMP by Risk Academy, with 16 of the course's 68 lessons covering trade finance, letters of credit, invoice manipulation, missing trader fraud, TBML red flags and the gold and diamond trades. TBML cases also appear in the CAMP AML Investigation Simulator.

This guide is part of CAMP by Risk Academy — the Certified Anti Money Laundering Professional programme: 68 video lessons, a graded AML investigation simulator and a final examination.

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