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The High Risk Ghost in Trade Finance

by Kim Sindberg | October 17, 2017

It is a fact that there is a perception that the Trade Finance Area is High Risk for the purpose of AML.

Auditors, regulators and compliance officers often make reference to external reports when arguing that the AML risk of Trade Finance is High. In my experience they make reference to the following:

* The Financial Action Task Force (FATF)
Report: Trade-Based Money Laundering. Published 2006

* The Wolfsberg Group
Report: The Wolfsberg Trade Finance Principles. Published 2011

* The Joint Money Laundering Steering Group (JMLSG)
Report: Prevention of money laundering/combating terrorist financing. Published 2011 (amended 2012)

* Financial Conduct Authority (FCA)
Report: Thematic Review 13/3 (TR13), Banks’ control of financial crime risks in trade finance (published July 2013)

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