Identify over-invoicing, under-invoicing, phantom shipment and multiple invoicing typologies in trade files.
Finance & Banking
Detecting Trade-Based Money Laundering in Invoices, Shipments and Payments
Prepares trade finance and compliance staff to detect over-invoicing, phantom shipments and document fraud, benchmark pricing and quantities against independent data, and escalate trade-based laundering typologies.
🗓️Duration5 training days
📚Content4 modules · 8 sessions
🎓On completionAccredited attendance certificate
About the programme
Course Overview
A single shipment of machine parts can generate a letter of credit, a bill of lading, an invoice, a packing list and a certificate of origin, and any one of these documents can be altered to move value that has nothing to do with the goods being traded. Over-invoicing, under-invoicing, phantom shipments and multiple invoicing of the same cargo let criminal proceeds and sanctioned trade move through banks that are looking at paperwork, not containers. This course works through the trade-based laundering typologies set out in FATF and Wolfsberg Group guidance, how to benchmark declared prices and quantities against customs and market data, and how letters of credit, documentary collections and open account terms each create different points of exposure. Participants examine real trade document sets for inconsistencies in weights, values, routing and counterparties, learn how dual-use goods and sanctioned end users are disguised in commodity descriptions, and practise building the escalation narrative that moves a trade finance query from a documentary discrepancy to a suspicious activity report.
Expected Learning Outcomes
Benchmark declared prices, weights and quantities against customs, freight and market reference data.
Examine letters of credit, bills of lading and certificates of origin for inconsistencies and alteration.
Assess dual-use goods and commodity description risk for concealed sanctioned end users.
Compare trade finance exposure across letters of credit, documentary collections and open account terms.
Escalate trade document discrepancies into a documented suspicious activity referral.
Design trade surveillance checks that flag routing, counterparty and pricing anomalies automatically.
Who Should Attend
Trade finance operations and relationship staff processing letters of credit and collections.
AML and sanctions compliance officers covering trade finance portfolios.
Correspondent banking teams assessing respondent trade finance exposure.
Customs and trade compliance professionals working alongside banking counterparts.
Financial crime investigators reviewing suspected trade-based laundering cases.
Commodity trading and export finance staff handling documentary risk.
Course Modules
Select any module to see its sessions and points.
01Trade-Based Laundering Typologies and Instruments
2 sessions · 8 points
Session 1Core Trade-Based Money Laundering Typologies
- Distinguish over-invoicing, under-invoicing and multiple invoicing schemes using worked trade examples.
- Identify phantom and short shipment patterns where paperwork exists without matching physical movement.
- Assess misrepresentation of quality, quantity or product description as a laundering technique.
- Map typologies against the FATF and Wolfsberg Group trade-based money laundering guidance.
Session 2Trade Finance Instruments and Their Exposure Points
- Compare documentary letters of credit, documentary collections and open account terms for laundering exposure.
- Assess the role of bills of lading, packing lists and certificates of origin as control documents.
- Identify how standardised trade messaging formats and correspondent banking chains affect visibility of underlying trade.
- Evaluate freight forwarder and letter of indemnity arrangements that can mask cargo discrepancies.
02Document and Price Verification Techniques
2 sessions · 8 points
Session 1Verifying Trade Documentation
- Cross-check invoices, bills of lading and insurance certificates for internal consistency.
- Detect altered, duplicated or inconsistent shipping and customs documentation.
- Verify counterparty details, vessel movements and routing against independent shipping data.
- Identify red flags in payment instructions that diverge from the underlying commercial contract.
Session 2Benchmarking Price, Volume and Commodity Data
- Benchmark declared unit prices against customs, commodity exchange and market reference data.
- Assess volume and weight declarations against vessel capacity and shipment history.
- Apply harmonised system code analysis to detect commodity misclassification.
- Identify dual-use goods and sanctioned end user risk hidden within generic product descriptions.
03Investigation and Escalation of Trade Finance Alerts
2 sessions · 8 points
Session 1Triaging Trade Finance Discrepancies
- Distinguish genuine documentary discrepancies from indicators of laundering or sanctions evasion.
- Request and assess supplementary documentation to resolve pricing or shipment anomalies.
- Coordinate with sanctions screening teams on flagged vessels, ports and counterparties.
- Apply a risk-based decision framework for accepting, querying or rejecting discrepant documents.
Session 2Building the Suspicious Activity Case File
- Compile a case file linking trade documentation, payment flow and counterparty history.
- Draft a suspicious activity report narrative that explains the trade-based laundering concern clearly.
- Coordinate escalation between trade operations, compliance and correspondent banks.
- Preserve trade documentation and communications for potential law enforcement requests.
04Programme Design, Technology and Governance
2 sessions · 8 points
Session 1Trade Surveillance Systems and Data Sources
- Design automated screening rules that flag pricing, routing and counterparty anomalies in trade data.
- Integrate customs, shipping and commodity price data feeds into trade surveillance systems.
- Evaluate vessel tracking and sanctioned port data as a control against sanctions evasion.
- Assess the limits of automated trade surveillance against sophisticated layering schemes.
Session 2Governance, Training and Regulatory Engagement
- Define roles and escalation paths between trade operations, compliance and sanctions functions.
- Report trade-based laundering typology trends and control effectiveness to senior management.
- Deliver targeted training to trade finance staff on emerging typologies and red flags.
- Prepare trade finance control documentation for regulatory examination and correspondent bank audits.
What the participant receives
4 course modules
A structured syllabus
8 training sessions
across 5 days
32 detailed points
Applied, detailed content
Accredited attendance certificate
On completing the programme
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