Trade Based Money Laundering (TBML) & Sanctions

Euromoney Learning Solutions

How long?

  • 3 days
  • in person

What are the topics?

Euromoney Learning Solutions

Disclaimer

Coursalytics is an independent platform to find, compare, and book executive courses. Coursalytics is not endorsed by, sponsored by, or otherwise affiliated with any business school or university.

Full disclaimer.

Reviews

Make sure this course is right for you.

Get unbiased reviews and personalized recommendations.

About the course

Banks who have failed to have adequate AML and sanctions compliance programmes and training in place have incurred penal fines, reputational damage and faced the potential loss or suspension of their ability to operate in certain currency markets or jurisdictions

This three-day workshop is focused on the associated AML and sanctions compliance risks in Trade Finance. It has been designed for correspondent bankers, trade operational and sales personnel and compliance officers to enable them to identify compliance risk zones in each of these product areas. The course uses a range of typologies, exercises and case studies to develop the understanding of delegates in a practical and engaging way across a range of scenarios

Training structure and methodology

Compliance risk; the compliance risks (AML and sanctions) associated with international trade will be described and how the use of red flags can identify suspicious activity

Trade products; the vulnerability of correspondent banking and trade products to abuse will be explained together with their compliance risk profile. Suspicious activity red flags will be highlighted and the ways to structure these trade products to reduce the risk of abuse. Each will be described in terms of its operation and compliance risk profile through presentational slides, diagrams and examples

Case studies; these will provide an opportunity for the delegates to consider relationships and transactions and identify the key risk compliance features, areas of due diligence and enhanced due diligence, and further information required to make a risk-based assessment

Each delegate will receive a workbook containing the presentational slides and supporting material

The case studies and exercises described are provided for indicative purposes only. The trainer reserves the right of discretion to vary the selection of case studies covered in the classroom depending upon the background, experience and key learning objectives of the delegates in attendance and classroom time availability

Objectives

By attending this training course, the delegates will understand the function, parties, role, operation, compliance risks and red flags of:

  • Correspondent banking; Its fundamental role in the movement of international money and trade flows The characteristics which result in high compliance risk
  • SWIFT messages: Vulnerability to compliance risk
  • Trade finance products; letters of credit, documentary collections and bank aval
  • Trade related guarantees, transferable guarantees and standby letters of credit
  • Pre-export finance
  • Trade receivables purchase finance

Agenda

Day 1

Introduction to compliance risk

  • The nature of compliance risk in cross border transactions
  • Why cross border transactions are a target for abuse

Anti-money laundering (“AML”)

  • The risk-based approach
  • An overview of the stages; placement, layering, integration
  • Suspicious transactions

Sanctions violation

  • Nature, purpose and impact of sanctions
  • Trade embargo and financial sanction (to include export licensing and dual-use goods)
  • Global reach; the importance and implications of the currency of payment
  • The compliance risk exposure of US dollar transfers
  • Bank exposure
  • Risk assessment

The cost of non-compliance

  • Case study; AML and sanctions violation

Correspondent banking

  • Introduction to correspondent banking; description, parties, function and operation
  • The vital role of correspondent banking in cross border money and trade flows
  • Gateway to compliance risk
  • Correspondent banking infrastructure:
  • Message authentication;
  • Nostro and vostro accounts
  • Exercise; due diligence and risk considerations
  • Correspondent banking; key areas of compliance risk
  • Recent market trends in respect of compliance challenges

Compliance risk; SWIFT

  • SWIFT message abuse:
  • Omitting information
  • Message stripping
  • Key compliance risk zones:
  • Originator; ownership, jurisdiction
  • Beneficiary; ownership, jurisdiction
  • Nature and value of transaction – ordinary course of business?
  • Screening – designated persons – sanctioned countries?

Trade based money laundering (TBML)

  • Common methods of TBML
  • Typologies; misrepresentation in price, nature of goods and multiple invoicing

Documentary collections

  • Description and operation
  • Parties
  • Types; DP, DA, Bank Aval
  • Compliance risk assessment and exposure
  • Product compliance risk profile

  • Case study; purchase of an avalised bill of exchange. Delegates will be required to undertake due diligence and identify further information required to undertake a compliance risk-based assessment of the transaction

Letters of credit

  • Description and operation
  • Parties
  • Key aspects
  • Example transaction
  • Trade documentation; compliance risk
  • Sanctions clausing
  • Fragmented bank roles; compliance risk exposure
  • LC confirmation; financial engagement and responsibility

Case study; the assessment of a potential money laundering cross border letter of credit transaction requiring delegates to identify key compliance risk issues and further information required to make a risk-based assessment

  • Compliance risk assessment; issuance, presentation of documents, payment:
  • Issuing bank
  • Advising bank
  • Product compliance risk profile

Case study; delegates will be asked to identify unusual features of a letter of credit request and identify the red flag suspicious activity characteristics

Day 2

Case study; delegates will consider a request to issue a letter of credit which is not in the ordinary course of business of the applicant and to identify the nature of the underlying transaction

Transferable letters of credit

  • Description and operation
  • Parties
  • Transfer changes
  • Product compliance risk profile

Case study; the assessment of a suspicious transferable letter of credit transaction. The delegates will be required to identify any unusual features, to identify key compliance risk issues and further information required to make a risk-based assessment

Synthetic letters of credit

  • Description and operation
  • Parties
  • Product compliance risk profile

Case study; delegates will examine a transaction and identify the compliance risk aspects

Standby letters of credit

  • Description and operation
  • Parties
  • Example transaction; commercial standby credit
  • Claim documentation; exposure to compliance risk
  • Its use in money laundering
  • Product compliance risk profile

Case study; delegates will be required to consider the course of action resulting from a suspicious claim under a standby LC and how the use of this product for money laundering can be reduced

Trade related demand guarantees

  • Description, operation and parties
  • The nature and compliance risk of “on demand” unconditional guarantees
  • Key aspects
  • The types and use of trade guarantees:
  • Advance payment (working example)
  • Transferable guarantees and associated compliance risks
  • An appreciation of URDG 758
  • Product compliance risk profile

Case study; the delegates will consider the compliance risk aspects of a request to issue a transferable letter of guarantee and the further information required to undertake due diligence. The delegates will be required to identify any unusual aspects and consider the course of action

Day 3

Receivables finance

  • Parties
  • Financing open account transactions; compliance risk exposure
  • Forms of receivables finance:
  • Selected debt purchase
  • Factoring
  • Product compliance risk profile

Case study; the delegates will be required to consider key aspects of due diligence on a request to purchase an invoice

Structured trade & commodity finance

  • Introduction; description, function and operation
  • Key compliance risk zones (in addition to those listed under trade finance)

Pre-export finance Description and operation

  • Parties
  • Compliance risk & due diligence

Typology; the use of commodity-based pre-payment to disguise the movement of illicit funds

  • Product compliance risk profile

Case study; delegates will consider the compliance risk aspects of a commodity-based trade finance transaction. The delegates will be required to construct a pre-export trade finance solution to validate the goods and control the release of payment

SUMMARY/CONCLUSION

Delegate pack only

COMPLIANCE RISK FRAMEWORK

RED FLAGS

  • Trade based money laundering
  • Sanctions

Experts

Stephen Jones

Stephen Jones is a highly experienced trade finance practitioner with over 40 years of trade finance expertise (35 of which was gained in the corporate banking environment). He has held senior trade positions in Lloyds Bank, NatWest and RBS.Stephen was the first in NatWest Corporate to win, struc...

Videos and materials

Trade Based Money Laundering (TBML) & Sanctions at Euromoney Learning Solutions

From  3565 GBP$4,799

Something went wrong. We're trying to fix this error.

Thank you for your application

We will contact the provider to ensure that seats are available and, if there is an admissions process, that you satisfy any requirements or prerequisites.

We may ask you for additional information.

To finalize your enrollment we will be in touch shortly.

Disclaimer

Coursalytics is an independent platform to find, compare, and book executive courses. Coursalytics is not endorsed by, sponsored by, or otherwise affiliated with any business school or university.

Full disclaimer.

Because of COVID-19, many providers are cancelling or postponing in-person programs or providing online participation options.

We are happy to help you find a suitable online alternative.