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AFB Financial Crime Masterclass: Mitigating Trade Based Money Laundering (TBML) in Trade Finance

This masterclass is designed to provide risk and compliance professionals with the knowledge and skills awareness to identify and manage financial crime risks in trade finance activity. It will provide a comprehensive update on managing TBML risks so firms can continue to facilitate legitimate trade while meeting regulatory expectations.

Attendees will gain enhanced confidence to identify higher-risk activity and apply practical, risk-based and proportionate systems and controls to identify, detect and respond to this activity in trade relationships and transactions.

Attendees will review core trade instruments and standards (ICC rules, including UCP for documentary credits and URC for collections), how trade is exploited by criminals, and the intersection with trade-related crimes (money laundering, sanctions evasion, tax crimes, unlicensed importation and export of dual-use goods and other predicate crimes).

Case Studies will be included on TBML, TBTF, tax crimes, sanctions, and dual-use goods.  The session will look at what happened, why it mattered, and how regulators responded, including the dos and don’ts, how to spot red flags, close control gaps, and sharpen screening, escalation, reporting, and record-keeping.

The use of technology will be included so that delegates are informed of some of the very latest developments that can be used to identify current and emerging crime risks relating to shipping.

COURSE CONTENT

During this masterclass, you can expect to learn more about:

  • Overview of trade finance: key products, parties, and why trade finance matters
  • Crime typologies: TBML, TBTF, and trade-related predicate offences
  • Regulatory framework (UK focus): POCA 2002, Terrorism Act 2000, Money Laundering Regulations 2017 (as amended); alignment with ICC rules (e.g., UCP 600)
  • Free Trade Zones (FTZs): operating models, risk drivers, and controls
  • TBML: Misrepresentation of price, quantity, and quality (over/under-invoicing, multiple invoicing, short/over-shipment, phantom shipments)
  • TBTF and managing the risks of weapons of mass destruction, arms and military and dual use goods
  • Trade-related predicate crimes including tax crimes, modern slavery and sanctions evasion
  • Navigating conflicts between UCP obligations and POCA reporting duties
  • Unusual indicators & red flags: jurisdiction, transaction/payment, customer/counterparty, documentation, and product risks
  • Reporting concerns: internal escalation, SARs under POCA and terrorism reporting; quality narratives and tipping-off risks

COURSE STRUCTURE

  • In person instructor led
  • Additional industry leading practitioners in the area will present
  • 3 hours of learning
  • CPD credits for any session attended
  • Key learning is supported using practical crime reports, peer-to-peer discussions and case enforcement analysis.

LEARNING OUTCOMES

By the end of this session, you will be able to:

  • Describe a range of trade-related financial crime risks including trade-based money laundering, financing of terrorism and proliferation, fraud and sanctions evasion
  • Outline the framework of systems and controls that are required to be operationalised to manage and mitigate crimes
  • List some specific trade-based money laundering typologies, such as the misrepresentation of value, quantity, and quality of goods, and how these are used to move illicit value from bribery, corruption, crime and terrorism.
  • Use red flag indictors to identify risks relating to the movement of illicit value through trade, financing of terrorism, and other predicate crimes such as sanctions evasion
  • Analyse regulatory case enforcement action to identify what went wrong when managing trade-related risks

WHO SHOULD ATTEND?

  • Trade finance teams and staff who contribute to the management of trade customer relationships and activities
  • Financial crime compliance professionals at all levels
  • All AML professionals who conduct customer due diligence checks and verification on trade customers
  • MLRO’s and their deputies
  • Line two and three risk professionals, including Internal auditors

LOGISTICS & BOOKING INFORMATION

Venue:       Central London venue -TBC

Date:          Wednesday 25 March 2026

Time:          09:00 – 12:30 (Registration and light breakfast from 09:00)

Price:         £410 plus VAT

For further information please contact secretariat@foreignbanks.org.uk