Table 5.

Interview questions

No.Interview questions
Section 1FFCs’ ability to identify TBML schemes and various techniques
Q1Have you ever heard of TBML?
Q2Have you come across these TBML techniques:
Q2.1The under- or over-invoicing of goods
Q2.2The over- or under-shipping of goods
Q2.3Multiple invoicing for goods
Q2.4Phantom/ghost shipping
Q2.5The inclusion of false descriptions for goods and services
Section 2Awareness of the existence of the FATF’s red flags and the presence of internal processes
Q3Are you aware of the FATF red flags that will assist in identifying TMBL schemes?
Q4Do you have processes to detect trade anomalies, like illogical shipping routes, pointing to TBML schemes?
Q5Do your internal processes verify beneficial owners?
Section 3Perceptions about collusion to commit TBML and the availability of reporting platforms
Q6Is collusion and PEPs’ involvement in exporting goods contributing to the commitment of TBML?
Q7Are reporting platforms available where trade inconsistencies can be reported to law enforcement?
Q8Are the identities of whistle-blowers kept anonymous?
Q9Has any feedback been received from law enforcement where cases were reported?
Source: Authors’ compilation

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