Trade Based Money Laundering Module 2: TBML Practices for Banking and Insurance Practitioners

Introduction 簡介

In recent global financial market development, banking trade finance facilities are being used to carry out money

laundering activities. Regulatory authorities have set up policies and regulations to combat these illegal activities.

Banking and insurance practitioners play a key role in the financial systems to control and avoid the risk of Trade

Based Money Laundering (TBML). The course is designed to introduce learners to the trade product features, latest

regulations and guidance, common red flags, trends and recommended risk mitigation controls and measures.

Programme Contents 課程大綱

Sample Reference Cases with TBML Risk Exposures and Consequence Management

• Unravelling an International Money Laundering Scheme Tied to Cyberfraud (Bahrain, FID)

• Dismantling International Illicit Finance Networks Through Mexico–U.S. Cooperation (Mexico and the United States, FIU-Mexico and FinCEN)

• Revealing the Many Facets of Cross-Border Money Laundering Scheme Through Diamond Trading (Israel, IMPA)

• Dissecting a Fake Export/Import Money Laundering Scheme (Korea, KoFIU)

Overview of Trade Products Features and Their

Vulnerabilities to TBML Risk Bank guarantees, Documentary collections, Financing under open account transactions, Forfaiting and risk participation, Import/export loans, Packing loans, Pre-shipment loans, Structured trade financing, Trust receipts, Warehouse financing, Import/export invoice discounting, Letter of credit (L/C) and Financing for transactions under L/Cs.

Highlights of Latest Regulations and Industry Guidance

Guideline on Anti-Money Laundering and Counter-Financing of Terrorism (For Authorized Institutions) and Anti-Money

Laundering and Counter-Terrorist Financing Ordinance (Cap. 615).

Common Red Flags in Handling Trade Finance

Transactions Customer Red Flags, Documentary Red Flags, Transaction Red Flags, Commodity Red Flags and Vulnerable Goods Red Flags.

Trends of TBML Typologies

Over-invoicing or Under-invoicing, Over-shipping or Shortshipping, Fictitious Trades, Use of Shell or Fictitious Companies, Multiple Invoicing of Goods and Services and Black Market Trades.

Recommended Risk Mitigating Measures, Controls and Best Practices

Trade Controls, CDD Procedures, Screening techniques, Expertise Training & Awareness, Assurance and Dual-use Goods.