Trade-based money laundering (TBML) was unearthed during investigations into ING Bank’s shortcomings in its anti-money laundering and counter financing of terrorism (AML/CFT) systems.

Earlier this week ING Bank paid a fine of €775 million (US$900 million) to settle a money laundering case with the Dutch authorities (Trade-based Financial Crime, 5 September 2018).

Women’s undergarments

The TBML case involved suspects who set up a limited company in the Netherlands  in 2010, which they used as a cover for their illegal financial services.

The company registered with the Dutch Chamber of Commerce as a pharmaceutical company with an office address in Amsterdam and a business address on Curaçao.

Shortly afterwards, the suspects changed the business objective to wholesaling women’s undergarments.

Suspicious money flows

Investigators found that the company never traded either pharmaceutical products or clothing.

Instead, they found several suspicious cash flows from and to the company’s bank account disguised as cash sales of clothing.

Payment service provider

Almost €150 million was credited from a German payment service provider. Payment service providers offer sellers services for accepting electronic payments by a variety of payment methods including credit card, bank-based payments such as direct debit, bank transfer, and real-time bank transfer based on online banking.

The credited funds were then immediately transferred to bank accounts in the US, Curaçao and Panama.