What can I do to prevent or detect it?

Supply Chain Roles in TBML Prevention

1. Stakeholder Responsibilities
Exporters, importers, freight forwarders, carriers, tax, and customs authorities, as well as
law enforcement and TCSPs, all play pivotal roles in tackling Trade-Based Money Laundering
(TBML).
2. Key AML/CFT Measures
To combat TBML effectively, supply chain participants must implement Anti-Money
Laundering and Counter-Financing of Terrorism (AML/CFT) measures, including customer
due diligence, compliance officers, robust reporting systems, and thorough internal records.
3. Enhancing Security with AEO Certification
Authorised Economic Operator (AEO) certification bolsters supply chain security under the
SAFE framework. It offers benefits like guarantee waivers and reduced customs compliance.

4. Practical Challenges and AML/CFT Application
While not all businesses may fall under formal AML/CFT controls, implicit TBML risk
mitigation principles exist in the FATF Recommendations. Caution is advised for TCSPs
handling client transactions outside their control.

5. Good Practices and External Expertise
Best practices include clear roles, risk identification, recognizing suspicious transactions, and
involving independent expertise. Collaboration with a wide range of experts enhances TBML
detection and prevention.
6. Utilizing "Big Data" Techniques
Leveraging "Big Data" for data mining and analysis, establishing Trade Transparency Units,
and following FATF best practice guidance can bolster TBML prevention.
7. Geographic Targeting Orders (GTOs)
GTOs can be effective tools for imposing reporting thresholds and additional record-keeping
requirements in high-risk TBML scenarios, as seen in various cases, including those related
to drug cartels.