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Compliance5 min read

Trade-based money laundering: typologies and mitigations in commodity flows

Over/under-invoicing, phantom shipments, and multi-party triangulation — how banks and traders identify them, and how to pre-empt them.

Trade operations floor with multiple monitors

Trade-based money-laundering (TBML) typologies catalogued by FATF and other bodies include over/under-invoicing, multiple invoicing, phantom shipments, and misrepresentation of goods. In commodity trades, triangulation across related parties is the headline risk — especially where free-zone vehicles, offshore counterparties, and conventional banks intersect.

Mitigation starts with reconciling documentary evidence (bill of lading, packing list, certificate of origin, insurance certificate) with operational evidence (ship movements, inspection reports, payment instructions). Inconsistencies — more than individual red flags — are the usual detection path.

Internally, a second-line compliance check before payment release, coupled with periodic sample reviews by independent reviewers, is the pattern banks like to see. For commodity traders, keeping the documentary chain clean pays back at correspondent banking and at audit time.

All commentary is general market context and does not constitute legal, tax, or investment advice. Obtain professional counsel for your specific transaction.