Trade Based Money Laundering

Understand how illicit value can move through international trade

An invoice can match a payment while the goods tell a different story. A shipment can be genuine while its price disguises an unexplained transfer of value. A complete document file can still leave important questions about what moved, who paid and who benefited.

This practical eBSI course helps you recognise those gaps and investigate the commercial explanation behind them.

Developed for the Export Academy and Trade Finance Academy audience, it examines TBML across the transaction lifecycle, connecting goods, documents, business relationships, logistics, finance and settlement.

Build practical judgement for the transactions you handle

Understanding TBML requires more than recognising a list of warning signs. You need to know what the transaction claims to represent, what the available evidence supports and how a discrepancy could change the movement of value.

Through worked examples and realistic fictional cases, you will learn to:

• Recognise how price, quantity and quality manipulation can transfer value between trading parties.

• Calculate apparent value differences and explain who receives the benefit.

• Compare invoices, packing lists, transport records, customs information and evidence of receipt.

• Examine unexpected payers, changed beneficiaries and intermediary arrangements.

• Test plausible commercial explanations against supporting evidence.

• Record unresolved concerns clearly and identify an appropriate next step within your authority.

The emphasis is on reasoned decisions. An unusual price, complex route or third-party payment deserves context and evidence before a conclusion is reached.

Who should take this course?

This course is designed for professionals who handle or review international trade transactions, including:

• Exporters, importers and SME business owners.

• Export sales, purchasing and international customer-service staff.

• Freight forwarders, shipping and logistics personnel.

• Customs brokers and trade-documentation staff.

• Trade-finance operations and relationship-management staff.

• Compliance, financial-crime and transaction-review personnel.

• Finance and accounts staff responsible for trade payments and reconciliation.

Different participants see different parts of a transaction. The course helps you understand the value of the information you hold, its limitations and where further evidence may be needed.

What you will study

1. Value in international trade

Establish how goods, money and information move through a transaction. Explore how trade can disguise illicit value and why a commercial irregularity alone does not establish money laundering.

2. Price and valuation

Examine over-invoicing, under-invoicing and unusual pricing. Work through calculations and compare prices on a consistent basis, taking account of specification, currency, delivery terms, freight, insurance, services and legitimate adjustments.

3. Quantity, quality and goods descriptions

Investigate over-shipment, under-shipment, phantom shipments and false descriptions. Learn how packaging conversions, missing goods and changes in quality can affect both the analysis and the apparent direction of value.

4. Trade documents and reconciliation

Build a coherent transaction picture from contracts, invoices, packing lists, transport records, customs data and receiving evidence. Distinguish what each document supports from what still requires independent verification.

5. Parties, ownership and intermediaries

Explore shell and front companies, beneficial ownership, trading capacity and intermediary roles. Examine circular trading, shared connections and the evidence needed to understand the commercial purpose of a structure.

6. Payments and open-account trade

Trace settlement back to the underlying obligation. Review third-party payments, group treasury arrangements, deposits, refunds, changed payees and multiple invoicing. Understand why records held by exporters and importers are particularly valuable in open-account trade.

7. Routing, logistics and customs

Assess unusual routes, transshipment, free trade zones, container and seal inconsistencies, freight charges and custody handovers. Distinguish country of origin from dispatch country and investigate discrepancies without overlooking legitimate operational explanations.

8. Trade-finance products

Compare the visibility and limitations associated with documentary credits, collections, receivables finance, pre-shipment finance and warehouse receipts. Examine duplicate-financing concerns and why documentary compliance does not settle every financial-crime question.

9. Practical review and escalation

Apply a structured review method: establish the expected transaction, reconcile the evidence, test explanations, assess unresolved concerns and document the next action. Practise asking neutral questions and writing clear escalation notes.

10. The Harbour Components case

Bring the learning together in an integrated fictional case involving a quantity shortage, a lower goods specification, an unfamiliar payer and changed refund instructions. Calculate the apparent value difference without double counting and prepare an evidence-based response.

Learn through practical examples

Consider a transaction in which a buyer pays EUR 120,000 for 1,000 premium components. Receiving evidence supports only 800 components of a lower specification, with a supported value of EUR 64,000.

The apparent difference is EUR 56,000. But a useful review goes further than that calculation.

You need to separate the quantity and quality issues, check for further deliveries or valid adjustments, examine the payer’s role and identify what the available evidence can actually establish.

This is the type of practical reasoning developed throughout the course.

What is included?

• 100 learning screens organised into ten chapters.

• Narrated teaching supported by on-screen text.

• 75 unique photographic illustrations and 25 explanatory diagrams.

• 20 deeper explanations exploring important concepts and distinctions.

• Ten practical decision activities with feedback explaining the consequences of different responses.

• Three captioned teaching animations covering value movement, document reconciliation and the integrated case.

• A searchable course and 24-term glossary for finding and revisiting key concepts.

• A full 44-page student manual containing the teaching content, worked practice explanations and reference material.

• A separate assessment drawing 20 questions from a bank of 50.

Check your understanding and review your result

The assessment selects two questions from each chapter and randomises both the question order and answer choices.

The pass mark is 80%, equivalent to 16 correct answers out of 20.

Once all questions are submitted, a results screen shows your percentage score, number of correct answers and pass/fail result. You can then choose:

• Save score and exit to accept your result.

• Retake the test to start again with a fresh selection of 20 questions from the bank.

A fresh selection may include some questions encountered previously.

Put the learning to work

The course gives you a repeatable approach to reviewing a trade transaction:

Establish what should happen. Check what actually happened. Explain the differences. Record what remains unresolved.

You will develop the confidence to ask more precise questions, recognise the limits of individual documents and produce a clearer record for the person authorised to make the next decision.

The learning draws on supplied trade-finance materials and FATF/Egmont TBML publications, with historical references identified in the course. Fictional cases provide opportunities to practise applying the concepts.

Strengthen your understanding of the trade behind the transaction

Whether you sell goods overseas, arrange their movement, process their documents or review their financing, your part of the transaction can reveal information that others cannot see.

Enrol in Trade-Based Money Laundering and develop a practical approach to recognising, reconciling and escalating unexplained value movements in international trade.