Trade-Based Money Laundering: Risks, Typologies and Controls

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Course Overview

Trade-based money laundering (TBML) is a recognised priority risk under FATF guidance and remains an area of heightened supervisory focus for UK-regulated financial services firms. Criminals increasingly exploit international trade, trade finance, and cross-border payments to move and disguise illicit funds, often leveraging complexity, volume, and fragmented oversight.

This interactive, workshop-led course is designed for senior compliance and financial crime professionals within UK-regulated firms who are responsible for overseeing trade finance, payments, and sanctions risk, and for advising the business on emerging financial crime threats.

The course examines how TBML operates in practice, drawing directly on FATF-identified TBML typologies and risk factors, including misrepresentation of goods, over- and under-invoicing, multiple invoicing, false trade documentation, and complex trade routes. It explores key risk indicators across customers, goods, jurisdictions, and transaction structures, and considers how these risks manifest across different trade finance instruments and payment flows.

The workshop focuses on how to design, operate, and evidence proportionate, risk-based TBML controls in line with FATF guidance and supervisory expectations. This includes risk assessment, customer and transaction screening, sanctions considerations, ongoing monitoring, escalation, and governance. Using realistic case studies, participants will strengthen their analytical and investigative capability and gain practical insight into how to assess whether TBML controls are effective and defensible.

Learning outcomes

By the end of the session, participants will be able to:

• Understand FATF’s approach to trade-based money laundering and why TBML is a priority risk
• Identify FATF-recognised TBML typologies and red flags across trade finance and payment activity
• Assess TBML risk drivers linked to customers, goods, jurisdictions, trade routes, and transaction structures
• Apply FATF-aligned risk-based principles to the design of TBML controls and monitoring
• Understand how sanctions risk and trade controls intersect with TBML exposure
• Evaluate the effectiveness of customer due diligence, transaction scrutiny, and escalation processes
• Evidence professional judgement, governance, and control effectiveness to supervisors, auditors, and senior management

Who this course is for

This workshop is designed for professionals with responsibility for TBML and trade-related financial crime oversight, including:

• Heads of Compliance and Financial Crime
• Trade Finance and Payments Compliance professionals
• Sanctions and Financial Crime specialists
• MLROs and Deputy MLROs
• Risk and Oversight Managers
• Internal audit and assurance professionals
• Senior managers accountable for financial crime risk

The course is particularly relevant for UK-regulated firms involved in trade finance, correspondent banking, or cross-border payments that need to demonstrate alignment with FATF TBML guidance and robust supervisory-ready controls.