Sunday 29 June 2014

Funnels


Another one on TBML
Trade Based Money Laundering is at the basis of the recently published advice on ‘funnel accounts’ – accounts in which illicit money is coming in from many sources, is used to buy and ship goods, which are then subsequently sold.
An article about this mentions that “ the main challenge is discerning between legitimate and illegitimate trade activity “. There is no rule book to describe what is allowed and what not. More than ever a risk based approach combined with adequate training of all staff involved in the operations of processing trade and payments transactions is required.
As the article indicates “ organisations are encouraged to make use of guidance, advisory notes, case studies and typologies as the basis of training “. And that’s exactly what we do in our TBML training.

Rolf

See also
http://www.fincen.gov/statutes_regs/guidance/pdf/FIN-2014-A005.pdf

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