Trade-Based Money Laundering in Practice: Sources and Further Reading

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Sources and further reading

The 25 sources below are the ones cited in the lesson reference boxes, grouped by type. Links open the publisher’s own page in a new tab. ICC rules are sold by ICC, so their links go to the ICC product pages. Publishers may move or update documents; if a link no longer works, search for the title on the publisher’s site.

International standards and typologies

SourceWhy read itLessons
FATF, Trade Based Money Laundering, 23 June 2006.The original FATF study: the definition of TBML, the basic techniques and why trade attracts launderers.1, 3
FATF, Money Laundering Vulnerabilities of Free Trade Zones, March 2010.How free zones' lighter oversight can be misused, with case examples.1, 3
FATF and APG, Money Laundering and Terrorist Financing Risks and Vulnerabilities Associated with Gold, July 2015.Why gold is an attractive vehicle for moving value, and the red flags.3
FATF and Egmont Group, Trade-Based Money Laundering: Trends and Developments, December 2020.Definitions including trade-based terrorist financing, the challenges, FIU analysis, the role of customs and public–private partnerships.1, 7, 8
FATF and Egmont Group, Trade-Based Money Laundering: Risk Indicators, March 2021.The four groups of indicators used throughout the course.1–7
FATF, Complex Proliferation Financing and Sanctions Evasion Schemes, 20 June 2025.Maritime and intermediary typologies where route checks meet sanctions.5
FATF, Investigating Professional Money Laundering, Underground Banking, and the Use of Hawala and Other Similar Service Providers, 3 September 2026.How professional networks combine hawala and underground banking with trade.1, 6
WCO and Egmont Group, Customs–FIU Cooperation Handbook, 2020.Announcement of the handbook on customs and FIU cooperation against trade mis-invoicing and informal value transfer.8

Industry guidance

SourceWhy read itLessons
Wolfsberg Group, ICC and BAFT, Trade Finance Principles, 2019 amendment, 2019.The industry baseline for financial crime controls in trade finance, including open account and the three lines of defence.1, 2, 4, 5, 8
AML/CFT Industry Partnership (Singapore), Best Practices for Countering Trade Based Money Laundering, May 2018.Practical controls: due diligence, document, price and vessel checks, and monitoring.2–6, 8
Hong Kong Association of Banks, Guidance Paper on Combating Trade-based Money Laundering, 1 February 2016.Risk-based controls, price checks for manifestly unusual prices, and the limits of automation.2, 4–8
Joint Money Laundering Steering Group, Guidance Part II, Sector 15: Trade finance, 2021.UK industry guidance on trade finance; find Sector 15 in Part II of the current guidance.2

Rules for trade documents and terms

SourceWhy read itLessons
ICC, Uniform Customs and Practice for Documentary Credits (UCP 600), 2007.The rules for letters of credit, including the principle that banks deal with documents.2, 5
ICC, International Standard Banking Practice (ISBP 821), 2023.How documents are examined under UCP 600.2, 5
ICC, Uniform Rules for Collections (URC 522), 1995.The rules for documentary collections.2
ICC, Incoterms 2020, 2019.Who pays for carriage, insurance and duties under each trade term.2
UK Parliament, Electronic Trade Documents Act 2023, 2023.The Act that gives qualifying electronic trade documents legal status in the UK.2, 8
UK P&I Club, The UK Electronic Trade Documents Act 2023 comes into force, 21 September 2023.A short practitioner note on what the Act means for electronic bills of lading.2, 8

Jurisdiction guidance

SourceWhy read itLessons
State Bank of Pakistan, Framework for Managing Risks of Trade Based Money Laundering and Terrorist Financing, revised, 12 August 2025.The circular letter issuing the revised framework.1–8
State Bank of Pakistan, Revised framework: annexures (red flags, typologies and case studies), 12 August 2025.The framework text with its red flags, typologies and eight case studies.1–8
Central Bank of the UAE, Guidance for Licensed Financial Institutions on Risks Related to TBML and Transshipment, 26 November 2025.Typologies, vulnerable sectors, illicit transshipment, controls and reporting expectations.1–8
Bangladesh Financial Intelligence Unit, Guidelines for Prevention of Trade Based Money Laundering, 2019.Risk scoring, review cycles, price verification and the decision on trade alerts.1, 4, 5, 7

Advisories and cases

SourceWhy read itLessons
FinCEN, Advisory FIN-2025-A003 on the Use of Chinese Money Laundering Networks by Mexico-Based Transnational Criminal Organizations, 28 August 2025.Mirror transactions, money mules and TBML; red flags and the reporting key term.3, 6, 7
US Department of Justice, Mexican nationals sentenced for roles in black market peso exchange money laundering scheme, 21 July 2025.A trade-based scheme that moved drug proceeds without moving cash across the border.3
US Department of Justice, Two year prison sentence for woman who laundered over $20M dollars, 2 February 2026.Business transactions presented as airline ticket purchases used to launder drug proceeds.3
Keep building

For evasion and maritime indicators, see Sanctions Compliance in Practice. For investigation and narrative writing, see AML Investigations and STR/SAR Reporting in Practice. For ownership and source of funds, see CDD and EDD in Practice.