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AFB Practice Workshop: Mind the Gap – The Pitfalls of Weak Trade Finance Controls

This in-person workshop, in partnership with Guidehouse, will examine real-life scenarios faced by banks providing trade finance services, and consider where shortcomings in financial crime controls may fail to prevent the potential facilitation of illicit activities.

The prevention of trade-based money laundering remains a focus for the UK regulator. The last comprehensive thematic review was conducted over 7 years ago. The FCA is now poised to examine this area, as indicated by the Dear CEO letter published in September 2021 and shown by follow on FCA and Skilled Person reviews targeting firms with significant Trade Finance activity. The surge in international trade in recent years has heightened the need for regulators to evaluate the effectiveness of existing controls and to ensure firms are adequately managing risk.

Why attend?

By examining a real-life case study in detail, this workshop aims to build a solid understanding from the ground up of what a “good” trade finance risk management programme looks like. It will explore the practicalities of transaction due diligence and ancillary quality frameworks, robustness of procedures and training, and ultimately the place of trade finance within a firm’s business-wide risk assessment.

The workshop will provide attendees with tips on how to implement a trade finance risk management programme and highlight insights on emerging trends both in terms of risks and mitigation practices.

Attendees will have the opportunity to take part in an interactive session with open questions, group discussions, and sharing of expertise by the team at Guidehouse. There will be a Networking Lunch from 12:00 – 12:30.

Who should attend?

Member representatives working in the following functions: Operations, Compliance, Legal and Risk.

Workshop Leaders

Priya Giuliani, Partner

Priya is a specialist in investigations & compliance with over 25 years’ experience. She is passionate about serving clients to solve their most complex and sensitive matters in efficient ways. Priya has a plethora of experience working with law enforcement agencies investigating trade-based fraud and money laundering. Her investigations background positions her well to help banks understand how risk manifests in financial institutions and how criminals can exploit systems and controls.

Priya has experience working with overseas banks heavily involved in trade finance. She regularly assesses the effectiveness of their trade finance controls across three lines of defence and provides recommendations (including as a Skilled Person) on how to meet regulatory requirements and expectations.  This includes acting as the Skilled Person or providing independent quality assurance to the FCA that each trade finance transaction meets regulatory requirements prior to execution. This experience allows her and her team to provide banks with specialist training and proportionate recommendations to enhance trade finance operations leading to improved compliance quality rates.

Noémi Klein, Associate Director, Financial Crime, Fraud & Investigative Services

Noémi is a financial crime compliance expert with over 10 years’ experience.  She has led and supported AML, Sanctions and Trade Finance functions within top tier global financial institutions and smaller regional banks with a specific focus on Africa, the Middle East, and Central Asia.

Noémi has developed her unique multi-dimensional FCC skill set building it from the ground-up to global, regional, and country leadership roles. Her expertise within sanctions, export controls and trade finance coupled with her deep understanding of geopolitical nuances enables her to provide tailored solutions for firms of all sizes. She has extensive experience in enhancing the effectiveness and efficiency of trade finance operations through successfully designing trade finance risk assessment and management frameworks. This includes bespoke policies and procedures in alignment with legal and regulatory requirements while embedding industry best practices.

As a trade finance expert, Noémi is regularly sought after to share her knowledge at specialist trade finance conferences, most recently at the S&P Global Market Intelligence Conference in April 2024, where she provided insights on how firms can navigate sanctions and export controls in trade. Noémi also contributed as a panellist at the Annual Trade Finance Compliance conference organised by the London Institute of Banking and Finance where she spoke about the changing regulatory and geopolitical landscapes and the importance of collaboration and technology.


Format:   In-person at Guidehouse, 1 Angel Ct, London EC2R 7HJ

Cost:        £255.00 + VAT

Date:       Wednesday 12 June 2024

Time:       09:30 – 12:30 (Registration and Breakfast from 09:30-10:00, Networking Lunch from 12:00 – 12:30)

Places:     Maximum of 30 people

If you would like to submit a question or have any specific areas that you would like the session to address, please send them to the AFB at You will receive details on how to join this in-person Workshop a week before the event. The Workshop will be held under the Chatham House Rule, to promote open and constructive discussion.