Advisory to Financial Institutions on Filing Suspicious Activity Reports regarding Trade-Based Money Laundering

The Financial Crimes Enforcement Network (FinCEN) is issuing this advisory to inform and assist the financial industry in reporting suspected instances of trade-based money laundering. This advisory contains examples of “red flags” based on activity observed in Suspicious Activity Reports (SARs) that may indicate trade-based money laundering.

While SARs are not proof of illegal activity, they can provide law enforcement with valuable indicators that this type of money laundering may be occurring. The examples discussed in this advisory are based on specific law enforcement experience involving

U.S. trade with Central and South America, but the types of activity detailed herein are by no means confined to those regions, and financial institutions are advised to take appropriate measures to mitigate the risks of analogous activity occurring globally.

Criminal organizations use the international trade system to transfer value across international borders and disguise the illicit origins of criminal proceeds. According to the 2009 International Narcotics Control Strategy Report (INCSR), it is estimated that the annual dollar amount laundered through trade ranges into the hundreds of billions. Additionally, U.S. Immigration and Customs Enforcement (ICE) reports that their tradebased money laundering case initiations have increased since 2004. The Financial Action Task Force (FATF) names trade-based money laundering as an increasingly important money laundering and terrorist financing vulnerability. FATF lists the physical movement of goods through the trade system as one of three methods criminal organizations and terrorist financiers use to move money for the purpose of disguising its origins and integrating it into the formal global economy.

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http://www.fincen.gov/statutes_regs/guidance/pdf/fin-2010-a001.pdf