Table 2.

TBML Risk indicator guidelines

Structural risk indicators
1.When the search business activity differs from the business line stated or the entity is not present online
 Structural risk indicators refer to the complexity that TBML schemes create using corporate structures, such as shell companies
Trade activity risk indicators
2.The entity’s transactions, shipping routes and general processes are inconsistent with standard business practices
3.A newly formed/re-activated trade entity engages in high-volume and high-value trade activities. In contrast, an unknown entity engages in trade activities in sectors with high barriers to market entry
4.Trade activity is inconsistent with the stated line of business of the entities involved, e.g. a car dealer that is exporting clothing
 The trade activity risk indicators refer to trade activities inconsistent with the stated line of business and complex trade deals involving numerous third-party intermediaries in incongruent lines of business
Trade document and commodity risk indicators
5.Contracts, invoices or other trade documents vaguely describe the traded commodities
6.Trade or customs documents supporting the transaction are missing and appear counterfeit. The documentation includes false or misleading information and is frequently modified and amended, including documents previously rejected
7.Where commodities are imported into a country under the temporary importation and inward processing regime, they are exported using false documents after the import
8.Goods and commodities are routed to jurisdictions and destinations that do not make commercial sense and cannot be justified
 Trade documents and commodity risk indicators refer to trade and customs documentation with vague descriptions or altogether missing documentation
Account and transaction activity risk indicators
9.An entity makes payment for imported goods using a shell company or company other than the consignee of the goods and commodities. The outside company’s involvement cannot be justified, and there are no economic reasons for the party’s involvement
 Account and transaction activity risk indicators include high-value transactions that are processed relatively quickly, followed by dormancy
Source: Authors’ compilation developed from FATF (2021b), Jancsics (2018) and Neverdauskas (2021) 

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