Table 1. Challenges in identifying TBML... | Emerald Publishing

Table 1.

Challenges in identifying TBML schemes

	Challenges	Discussion	References
1.	A lack of awareness of the existence of TBML	FFCs facilitate the movement of goods with a limited connection to the movement of the associated funds Role players are unaware of the FATF’s TBML trends and associated red flags	(FATF, 2020) (FATF, 2021a)
2.	Trade processes are paper-based	The detection of suspicious transactions using digital forensic data analysis is impossible if documents are paper-based Paper-based documents create opportunities to manipulate trade documentation	(Casanova et al., 2022)
3.	Large sections of the trade system are unregulated	The trading system is largely unregulated, making compliance with anti-money laundering (AML) or financing of terrorism laws less critical FFCs can unknowingly be involved in facilitating TBML just by their involvement in facilitating the movement of goods	(Chung et al., 2020)
4.	An inability to identify beneficial ownership	Ownership structures can be fabricated using complex structures and shell companies in various jurisdictions Falsified customer information will not flag trade anomalies. The use of shell companies with ownership below 5% will result in an exemption from the declaration of beneficial ownership information	(Naheem, 2015; Gilmour, 2022) (CIPC, 2023)
5.	A disconnect between multiple domains	Investigative authorities monitor predicate offences FFCs focus on the movement of goods with a limited focus on the movement of funds Financial institutions focus on the movement of funds, and customs authorities focus on collecting correctly calculated taxes	(FATF, 2020) (Greenburg et al., 2023)
6.	Advanced import payments	Advanced import payments can proceed without visibility of the goods As money moves between jurisdictions, a disconnect is created between the movements of goods and funds	(Neale, 2019; Gilmour, 2022)
7.	Customs officials are unable to verify the content of all containers	Less than 5% of all containers are inspected at the ports Criminals can hide the true nature of goods, opening the door to various illicit strategies	(Sinno et al., 2023)

	Challenges	Discussion	References
1.	A lack of awareness of the existence of TBML	FFCs facilitate the movement of goods with a limited connection to the movement of the associated funds Role players are unaware of the FATF’s TBML trends and associated red flags	(FATF, 2020)(FATF, 2021a)
2.	Trade processes are paper-based	The detection of suspicious transactions using digital forensic data analysis is impossible if documents are paper-based Paper-based documents create opportunities to manipulate trade documentation	(Casanova et al., 2022)
3.	Large sections of the trade system are unregulated	The trading system is largely unregulated, making compliance with anti-money laundering (AML) or financing of terrorism laws less critical FFCs can unknowingly be involved in facilitating TBML just by their involvement in facilitating the movement of goods	(Chung et al., 2020)
4.	An inability to identify beneficial ownership	Ownership structures can be fabricated using complex structures and shell companies in various jurisdictions Falsified customer information will not flag trade anomalies. The use of shell companies with ownership below 5% will result in an exemption from the declaration of beneficial ownership information	(Naheem, 2015; Gilmour, 2022)(CIPC, 2023)
5.	A disconnect between multiple domains	Investigative authorities monitor predicate offences FFCs focus on the movement of goods with a limited focus on the movement of funds Financial institutions focus on the movement of funds, and customs authorities focus on collecting correctly calculated taxes	(FATF, 2020)(Greenburg et al., 2023)
6.	Advanced import payments	Advanced import payments can proceed without visibility of the goods As money moves between jurisdictions, a disconnect is created between the movements of goods and funds	(Neale, 2019; Gilmour, 2022)
7.	Customs officials are unable to verify the content of all containers	Less than 5% of all containers are inspected at the ports Criminals can hide the true nature of goods, opening the door to various illicit strategies	(Sinno et al., 2023)

Source: Authors’ compilation