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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