Lawyers working for Pillsbury Winthrop Shaw Pittman LLP have written an interesting commentary on trade-based money laundering (TBML) in relation to the US Bank Secrecy Act (BSA).

They advise that both domestic and foreign financial institutions should review anti-money laundering (AML) procedures in the light of the growing interest of regulators in trade-based financial crime.

New frontier

The authors describe TBML as the ‘new frontier’ in terms of the BSA and subscribe to the view that an estimated 80 per cent of the world’s illicit money flows stem from trade-related activities.

This, they say, means that AML regulators and prosecutors are progressively turning their enforcement focus to TBML and scrutinising financial institutions’ trade finance compliance programmes for potential AML violations.

Trade finance focus

As authorities are continuing to take an increasingly tougher stance on banks’ failures to comply with the BSA, the lawyers advise that domestic and foreign financial institutions operating in the US should promptly assess their TBML compliance policies and procedures.

As a result of these assessments, financial institutions should make improvements, where needed, in relation to their trade-related activities.

The full commentary by lawyers from Pillsbury Winthrop Shaw Pittman can be found here

The lawyers point to a useful case study on TBML, which can be found here