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Trade based money laundering: Trade based

money
towards a working definition for laundering

the banking sector

Mohammed Ahmad Naheem 513
Seven Foundation, Zurich, Switzerland

Abstract
Purpose – This paper aims to explore in depth some of the main criminal elements involved in
trade-based money laundering (TBML) and outlines the gaps in banking risk assessment as a result of
this. The focus is on new and emerging risks due to criminal manipulation of the anti-money laundering
(AML) risk assessment processes.
Design/methodology/approach – The paper uses secondary data to provide the current context in
which TBML risk assessment is being carried out and how criminals have responded to this; it
concludes the empirical section by surmising the emerging risks that AML risk assessment need to
consider. The paper then introduces the basic components that future theoretical frameworks looking at
banking AML risk assessment would need to consider. This includes a more in-depth understanding of
how criminals are bypassing AML risk assessment so that countermeasures can be put in place and
AML frameworks strengthened and updated.
Findings – The main findings are that sophisticated criminal processes exist that can be used to
bypass and divert current banking risk assessment techniques. An overdependence on traditional
customer due diligence and transaction monitoring can easily be thwarted, and banks need to develop
a stronger AML assessment framework.
Research limitations/implications – The research focused primarily on client documentation;
however, another area of research would be needed to cover criminal manipulation of trade documents
and other components of TBML transactions.
Practical implications – The implications from the research affect any financial organization
undertaking AML risk analysis or compliance. It applies to the banking, insurance and auditing
professions, as well as is of interest to academics working on TBML projects.
Social implications – The social implications are that non-criminal clients within banks could be
faced with tougher requirements for documentation and ID proof, which could reduce efficiency and, if
not handled properly, even alienate further some sectors of society who are already struggling to access
the main banking and financial services sectors.
Originality/value – The originality of this paper is the inclusion of criminal responses to TBML risk
assessment and a review of flaws and gaps in AML risk assessment procedures. Dynamic risk
assessment needs to be continuously updated and new emerging market risks appropriately addressed.

The author thanks Professor Muhammad Jum‘ah (a leading economist of this era based in
Damascus), who has continued to provide valuable input both through his teaching of the science
of economics and for his continued guidance.  Journal of Money Laundering
The author acknowledges being the recipient of a research grant awarded by Princess Alae as Control
Vol. 18 No. 4, 2015
part of Seven Foundation’s “2020 Banking Vision – Building Banks of the Future”, and thanks her pp. 513-524
for the continued support and motivation both to himself and other students who benefit through © Emerald Group Publishing Limited
1368-5201
her generosity (www.sevenfoundation.ch). DOI 10.1108/JMLC-01-2015-0002
JMLC This paper highlights some of the current and emerging AML risks for the banking and financial
services sector.
18,4
Keywords Beneficial ownership, Risk based assessment, Global banks,
Trade-based money laundering (TBML)
Paper type Research paper

514
Introduction
Trade-based money laundering (TBML) has been identified as one of the newest and
possibly most complex forms of money laundering to affect the banking, anti-money
laundering (AML) compliance and regulatory sectors (Araujo, 2008). The rapid
expansion of the global trade sector (APG, 2012) along with increased technology has
provided an ideal environment for money launderers to transport illegally gained
money, either in cash or through goods, across the world. However, despite the long
history of known and established money laundering offences, the diversity of
trade-based options for laundering has meant that the definition of TBML is still vague
and unclear (Soudijn, 2014). Although the name TBML includes the term “money
laundering”, which implies cash transactions of some kind, in reality it focuses almost
exclusively on the falsified use of documents and shipping information to transfer goods
and services (AUSTRAC, 2013), hence the term trade-based. This level of complexity is
highlighted in the Financial Action Task Force (FATF) definition, which does not
include the term money or cash at all but instead uses the term value. “the process of
disguising the proceeds of crime and moving value through the use of trade transactions
in an attempt to legitimise their illegal origins or finance their activities” (Financial
Action Task Force, 2014, p. 5).
While there is still ongoing debate about definitions of TBML, there is perhaps
another question that remains to be answered: What has all of this got to do with the
banking sector? If TBML is concerned with the movement of value through goods/
services, most of which occurs outside the formal banking sector (Ferwerda, 2012), why
is pressure being placed on banks to intervene in this process? This paper explores the
banking exposure to TBML and considers how banks are used as part of the TBML
chain of activity. The paper then seeks to clarify how banks can become involved in the
detection and prevention of TBML through their services. To understand how TBML
operates, the perspective of the criminal is also considered in this paper, to illustrate how
TBML detection will have to be an ongoing and evolving process. A dynamic form of
risk assessment framework is proposed and discussed, as part of the solution for the
banking sector.

Trade finance
To understand how TBML activity occurs, it is first necessary to understand how trade
finance operates in legitimate trading transactions. The main trade agreements are
made between a buyer, who provides payment, and the seller, who provides the goods.
As most buyers will only pay for goods after or upon receipt, the seller needs to raise
some form of trade finance for the transaction to occur. This is known as pre-shipping
finance (APG, 2012). It is a key role of financial institutions to provide trade finance to
the sector and this can be done through a number of means and involves using some or
all of the trade documents mentioned in the following text.
Bills of exchange Trade based
Bills of exchange are bank drafts for exporters, which also give details of when payment money
will be made, and which bank issued the draft and may include other documents such as:
laundering
• Commercial invoices: Gives information on the weight and description of goods.
• Transport document: Often known as a Bill of Lading, which provides details of
the agreed goods for carriage and details of the shipping arrangements.
• Insurance document: For the goods while in transit.
515
• Certificate of origin: Which states where the goods were produced.
• Certificate of inspection: Provides an additional opinion on whether the goods are
as stated.
• A packing list: Often used when the consignment is divided into smaller packages.
• A weight certificate: Used by buyers when goods are sold by weight, also used by
freight companies to determine the cost of transport.

Occasionally, sellers accept other systems such as countertrade or buying back

purchases produced by the buyer, instead of cash payments. As these are all negotiated
locally, they are difficult to monitor and are left as vulnerable techniques for TBML
customers to exploit.

Letters of credit
Letters of credit is an older system for offering assurance of payment by importers.

Open account facilities

Open account facilities are the more modern way of facilitating credit for importers and
include some of the following techniques:
• Factoring: The use of intermediary houses that purchase the invoices and
follow-up on the buyer’s payment.
• Import factoring: Which is a form of insurance undertaking by the importers,
whereby the factor follows up on the seller and the goods to be acquired and
checks shipping documentation.
• Forfaiting: Where the exporters invoice is paid, for a fee, by the forfeiter and the
importer now owes the debt to the forfeiter rather than the exporter.
• Commodities funding: Some commodities such as precious metals have a stable
value and funds can be advanced as credit on the expected value of the goods. If
the sale does not go ahead, then the funders receive the equivalent value of the
goods.

Illicit trade
Illicit financial flows account for approximately 3.5-5.7 per cent of the gross domestic
product across the globe (Kar and LeBlanc, 2013); however, to accurately depict TBML
patterns, a detailed collection of data on the buyers and sellers, as well as the goods and
methods of transportation are all required, before an accurate picture of illicit trade can
be properly established. Research by Hong et al. (2014) focused on the specific trading of
bananas between the USA and the Caribbean and Latin America. In their work, they
focused on a 10-year period and calculated by the weights and quantities, how much
JMLC discrepancy existed between global trade prices and those in the US study. They looked
18,4 at three different methods for analysing trade patterns.
The first was partner country trade data comparing exports and imports stated
between both countries. The second was the price filter analysis approach which uses an
arms-length calculation for each product, set against a maximum and minimum set of
values. The final method supported by the research was an arms-length approach again,
516 but this time using US data UNCTAD (UN Conference on Trade and Development), with
the range being 10 per cent either side for the maximum and minimum range. Their
study highlighted how some trade data filter methods can obscure the activities that are
actually taking place and are not able to detect the anomalies in pricing for certain
situations.
There are therefore a number of ways in which TBML can occur, and several money
laundering techniques can be used at the same time in a TBML transaction (AUSTRAC,
2013). Some of the ways that affect banking risk assessment are:
• price misrepresentation (over- or under-invoicing);
• fictitious invoicing (for goods that do not exist);
• multiple invoicing;
• falsely describing goods or misrepresenting the quality or quantity of goods;
• legitimate shipment of goods between criminal groups;
• ghost or phantom shipments (paperwork exists but goods were never moved); and
• disguising laundered funds as consultancy or other service-related fees.

All of these systems leave areas of vulnerability for TBML to occur; the message to
banks is that fraudulent use of documentation can occur at any of these levels. This is in
addition to the possibility of collusion between parties, which can be used to facilitate
money laundering rather than ordinary trade transactions. Some of the above factors
can be recognized and flagged as alerts, especially if risk assessments are detecting a
number of concerns, including difficulty in establishing the true ownership of the
business, and/or a lack of information on the bank customer. The next section looks at
some of the adaptations that criminals have made to circumvent recent AML regulation
in the financial services sector.

Criminal traders
Criminals can adapt in a multitude of ways to exploit weaknesses or gaps in any
financial trading system (Curtis Williams, 2013). One of the ways for clients to avoid
detection in customer due diligence (CDD) risk assessment is through the use of a false
identity. Buying fake identities appears to be a fairly straightforward process on dark
net sites, such as Angora (Deepdotweb, 2008), or through other sites dealing specifically
with false passports (Aplus, 2014). The increase in sites available for these types of
purchases highlights the growing problem in false identity trade. The rise in cybercrime
(FATF, 2014) means that as well as using false identities, criminals are also using stolen
credit card details, stolen details from PayPal or other Internet payment systems and
forged details on other forms or documents needed by the bank to support and verify
their new identity. In short, it is no longer acceptable for a risk assessment framework to
accept identity documentation at face value, and instead, this needs to be used in Trade based
conjunction with other risk factors. money
This is a growing concern across many countries, as documents can be falsified for a
number of reasons including terrorism, underage drinking as well as identity theft and
laundering
money laundering. Law enforcement officers are slowly being trained in the skills used
for detecting the use of false identities (PIRE, 2011), and some of these skills could be
used by banking officials in their beneficial ownership and CDD assessments. Skills 517
such as knowing that owners of false identities will have to remember all their new
details, and therefore, questions on CDD or beneficial ownership information (BOI)
assessments should avoid using straightforward recall answers.
One solution criminals use to avoid running into problems with the initial CDD
checks is to use people as fronts to their own activities. These people may be existing
clients in the bank or new clients who have no apparent connection to the criminal
organization (Egmont Group, 2000). These clients are known as “Straw Men” and will
pass initial banking CDD checks to enable the criminal organization to carry out their
transactions undetected. In these situations, banks need to be aware of monitoring
account activity as well but also to use BOI. The BOI becomes even more important in
these situations to determine who is actually behind the flow of money and to track
where the money is actually going (Figure 1).
In addition to falsifying identification documents, clients involved in TBML
activities can also present other business documentation to the bank that has been
altered, forged or acquired illegally. The nature of the forged document will depend on
the transaction that they wish to undertake and the underlying purpose of the criminal
activity, therefore understanding the nature of the business may give some clues as to
the nature of the crime. One form of TBML activity is to overestimate the price of
invoices. In other words, a client in the UK may have purchased 100 watches valued at
€10 each with an invoice total of €1,000 and wishes to sell these to an oversees buyer in
Pakistan. However, the invoice shown to the bank for the shipping value shows the
watches at €100 each and is for a total of €10,000. Although this may be presented as a
markup price, this is clearly beyond a standard profit margin. Instead, it could be a sign
that money is being laundered into the country, with the buyer in Pakistan paying

Figure 1.
UK passport
JMLC €10,000 to the seller, but only €1,000 is the cost of the watches and the invoice given to
18,4 the buyer only shows receipt for €1,000. The remaining €9,000 is laundered money that
the buyer wants to send into the UK, which the seller will deposit into another account
shortly after receiving it. In this arrangement, the bank is being used as a remittance
system for laundered money between Pakistan and the UK.

518
TBML typologies
Developing a system of typologies is one method that might support the bank, so that
AML officers know the types of activity to look out for. This could include looking for
sudden withdrawals of large amounts of cash especially after receiving a shipment of
goods that could be valued at a lot lower than documents show.
One of the ways that criminals can overcome some of the transaction regulation is by
using external allies to circumvent restrictions on deposit amounts or add confusion to
the financial trail. The classic method is to take a large cash sum, for example €100,000,
and to break this down into smaller sums of between €8,000 and €9,000. A number of
members of the gang or outside members such as family or friends are given batches of
the money and ordered to deposit it from different banks locally to arrive at the same
destination bank. This process is known as smurfing and it was devised to avoid
detection when large sums of cash needed to be deposited (Egmont Group, 2000).
However, as banks have become more aware of this process, other more complex surfing
activities have been developed.
The first is cuckoo smurfing, where like the cuckoo bird who sneaks its eggs into
other bird’s nests and lets them hatch and rear its offspring, the cuckoo smurf also
infiltrates a legitimate financial transaction and diverts it for its own end. The criminal
gang uses the knowledge of legitimate accounts and transactions and hijacks this
information for money laundering purposes without the account holder’s knowledge. No
money is taken from the account holder, but the knowledge of the type and amount of a
transaction is hijacked for the criminals to alter to suit their own means. Usually this
entails diverting legitimate money in the middle of a trading transaction and replacing
it with dirty money.
For example, a Company A in Pakistan wishes to purchase a product from a
Company B in the UK. The criminal gang based in the UK have contacts in Pakistan,
where they wish to launder money into the local banking system. The Pakistan
Company A uses a local remittance service, which the criminal gang have a member or
contact in. They learn that £X, 000 is being transferred by Company A into the Account
123 belonging to Company B. The criminal contact in the remittance service takes the
money from Company A and hands it to the criminals who have now obtained clean
money from a legitimate business. They in turn instruct their contacts in the UK to take
the dirty cash and deposit it through a number of local bank accounts into Account 123
on a certain day. Company B receives the funds and Company A has paid the money for
the goods. The criminal gang has also laundered £X, 000 into the Pakistan banking
system, which can then be legitimately transferred into the UK bank system at a later
stage.
For the banking sector generally, but especially for global banks who are involved in
international transfers, there are a number of factors that need to be acknowledged when
implementing AML regulations. Trade finance is one of the most important aspects of
maintaining the economy (FCA, 2013) along with confidence in the banking sector.
TBML therefore has the potential to distort and upset both of these components if Trade based
appropriate regulation and control is not maintained. However, the main question to be money
asked is how does TBML affect banking business and why does the financial sector
need its own understanding and definition of TBML?
laundering

TBML definition in banking

For the banking section, the everyday use and definition of TBML is most commonly 519
used during the risk assessment of a client’s overall business proposal. This is part of a
standard “Know Your Customer” approach; however, the additional TBML component
is to determine the source of the materials being used (cash/goods or services) and to
assess whether these are feasible for the business proposition under consideration. The
bank cannot determine whether these goods or money are from illegal gains, but it can
highlight whether it is possible to run this proposal using cash or goods acquired
illegally or whether another form of business might be operating in the background.
In this context, perhaps a more accurate definition of TBML for the banking sector
would be “The use of the financial services to facilitate the movement of money, through
the use of fraud or deception”. This clearly defines the role that banks have in engaging
with TBML activities, because the deception process will have compromised their own
systems of risk assessment. The use of the term “money” is important to reintroduce into
the banking context because that is the part of the TBML transaction that will manifest
in the bank risk assessment.

AML regulation in banking

At a practical level, therefore, there are a number of AML measures that banks
implement, as part of their regulatory and risk assessment processes, which can be
adapted to accommodate this new definition of money laundering and trade financial
fraud.

Customer due diligence

The first of these is the CDD and enhanced due diligence (EDD) systems (Mugarura,
2014), whereby client information and background account information are gathered.
Clients need to satisfy a number of criteria before the bank is willing to work with them.
However, from the information above and in light of the newly proposed definition of
TBML for banks, there is now one important element to be considered in the old AML
system:
• CDD checks and EDD risk assessments are only effective if the information can be
verified.
• If the information cannot be verified or raises suspicions, this needs to be noted.

The increasing use of legitimate businesses as front companies is one way in which
criminal syndicates have sought to circumvent many of the risk assessment processes
(FCA, 2013). This means that initial CDD checks in these situations will show that the
client documentation can be verified and be valid. However it is at the second level of
checks, seeking beneficial ownership, that the bank can begin to unravel some of the
deception. Other factors such as unusual business transactions for this client and
sudden changes in transaction patterns can flag to the bank that something is amiss.
JMLC Beneficial ownership
18,4 This is not a regulatory requirement in all countries, but it is becoming stronger in light
of recent money laundering cases, especially in the USA. It focuses on establishing who
the actual benefactor of a business is, rather than the traditional approach of listing the
named shareholders or shell companies that might be operating under that name.
Beneficial ownership is seen as moving one step closer towards unravelling where
520 financial transactions might be originating from or ultimately heading towards.
Although banks might complain that this is another layer of paperwork (Pellegrina and
Masciandaro, 2008), perhaps from the new definition, it is apparent that it might be a
more cost-effective process than other methods of verifying business transactions:
• Determining beneficial ownership becomes a priority over checking shipping and
lading information, as the latter can all be falsified.

Multiple banking partners

A final risk assessment area that is often used is to check the AML requirements of
partner banks that might be involved in the transaction. However, from the new
definition, it is possible that other banks have perfectly good AML requirements, and if
they do not, then, ironically enough, they will be more vulnerable to easier methods of
transporting cash rather than TBML transactions (Ferwerda, 2012). Instead, the very
fact that multiple banks are involved should be a trigger in its own right, but again the
assessment should be made against the overall business viability of the client’s
company.
Transactions involving multiple banks should trigger a system of checks that seek to
establish the overall viability of the business, rather than focusing only on the area that
funding is sought for. In this assessment system, which does not have to be too detailed,
the following points should be considered:
• Is there an undue amount of complexity involved in the shipping and movement
of goods?
• Are there sound business reasons for choosing the export countries and shipping
routes?
• Would a normal business transaction of this nature make the expected financial
returns that the client is predicting or showing has happened?
• Could this business achieve the same expected outcomes using illegal goods,
laundered money or falsified information at any stage?

Additional sources of data

The use of trade data analysis has been proposed as one way in which law enforcement
and customs officials can thwart price alterations and changes to weights of shipments.
It focuses on four key areas of interest, which are country, customs district, product and
transaction price risk characteristics (Zdanowicz, 2009). As this information is often
collected by different agencies at different points in the trading process, there is a strong
need to share data across agencies and increase interagency cooperation (FCA, 2013).
The introduction of Trade Transparency Units in the USA now offers one example of
an interagency model to illustrate how cooperation and sharing of trade data can benefit
those working to combat TBML transactions (Zdanowicz, 2009). Table I was part of the
research project undertaken by Zdanowicz (2009) and provides examples of how trade Trade based
prices can be distorted through criminal activity. money
Access to trade data is considered by the FCA (2013) to be one component to
introduce and develop effective TBML regulation into the banking and financial
laundering
services sectors. How this will be achieved has yet to be determined. In general though,
a risk-based approach to AML compliance should enable banks to use their own
flexibility and incorporate simple business viability models, to determine the likelihood 521
of whether the client’s business proposal is legitimate or not. This would move the focus
of banks away from determining the source of the money and instead focus on the
business model being presented to them. There will still be questions asked in relation to
whether there is a risk of illegal money being used or whether by funding, this
transaction illegal activity will occur. If during the course of their analysis, flags are
raised, then outside sources of expertise can be brought in.
In law enforcement, there has to be a clear pattern of criminal activity for a successful
conviction to occur, so perhaps banking and legal definitions of TBML need to overlap
at some point. For a fraudulent transaction to be successful in banks which implement
robust AML compliance measures, then the client undertakes some form of deception or
fraud. It is this element of deception and fraud that is the responsibility of the bank to
uncover, as it is undermining their own risk analysis of the business being undertaken
not to do so.
At the end of the day, the bank specializes in supporting business transactions and
can make one of two decisions regarding each application made by a client – either the
business proposal is viable or it is not. However, in TBML transactions, and as these
often cannot be differentiated from normal trade transactions, therefore this applies to
all transactions, there is an additional question: Can these outcomes also be achieved
through the use of illegal goods, laundered money or falsified information?

Theoretical framework for banking TBML risk assessment

Most of the research studies on banking and risk assessment have focused on the
empirical challenges to banks and the operational impact of AML regulation; however,
some studies have also explored the theoretical context and possible frameworks that
could be used to explain TBML in the banking domain.
The principal–agent model is perhaps the most common model used to explain the
bank’s rationale for either implementing or not implementing AML regulation (Araujo,
2008; Pellegrina and Masciandaro, 2008; Shah, et al., 2006). According to Araujo (2008),
the higher the profits that can be made through illegal activity, the less willing a bank
will be to implement AML regulation. This is an argument that also applies to other

Product Country Average price World average price

Cooking stoves Colombia $76.62/each $425.65/unit

Erythromycin Iran $0.10/gram $1.20/gram
Nickel alloy wire Venezuela $2.21/kg $12.26/kg
Herring bone tire France $7.69/each $192.25/unit
Machine guns France $364.08/each $2,022.67/unit Table I.
Enriched uranium-235 Spain $15.50/kg $172.22/kg US exports at low
Military rifles UK $106.87/each $387.55/un average prices
JMLC financial support services such as external auditors, who are expected to override their
18,4 commercial interests to report suspicious activity (Aslani et al., 2012). Instead, Araujo
proposed an incentive-based approach to suspicious activity reporting rather than an
increased regulatory response. Pellegrina and Masciandro also suggested that increased
punitive regulation would not necessarily increase AML implementation within banks.
Other theoretical frameworks that have been suggested include systemic theories of
522 information and data sharing across units within the banks (Angell and Dionysios,
2005), and systems theory has also been used where insider contacts within banks are
used as part of the financial crime, such as the LIBOR scandal (McConnell, 2013). Other
theories of criminal behaviour such as crime displacement (Soudijn, 2014) and
white-collar crime (Hansen, 2013) have explored, from a criminology perspective, why
banks and financial institutions may become vulnerable to insider support for financial
crime. This is an issue that is particularly relevant to global banks that have affiliate
banks in countries where poverty and corruption have greater influence. Bank officials
in these locations are likely to be under greater risk from criminals using bribery
techniques, thus banking and AML regulation is more vulnerable to being exploited.
A theoretical framework for TBML would have to consider a number of angles,
including the impact of regulation on governance and AML compliance decisions within
the bank, the tactics and approach of criminal clients and which AML systems within
the bank are likely to be most vulnerable to being exploited. This would depend on the
given location of the bank, the investigation skills of the staff and the expected use of the
banking services by the criminals.

Conclusion
In conclusion, it has been suggested that TBML risk assessment is an evolving process
that impacts across the entire financial services sector. Despite the gradual development
of AML regulation, recent research from the FCA (2013) has highlighted the
inconsistencies in risk assessment among banks and the limited use of specific
trade-based risk assessment tools. Historically, the standard risk assessment
approaches for money laundering have focused purely on financial transactions,
especially the movement of large sums of cash. However, the focus in recent years has
also looked at the client’s behaviour combined with suspicious transaction activity (He,
2010), such as holding multiple accounts, spotting transactions that are unrelated to the
nature of the business being run and clients using offshore or high-risk country
accounts.
The ongoing development in TBML risk assessment has now further developed to
also focus on determining the actual ownership of businesses and companies named in
transactions. This has been brought to attention, as money launderers have evolved
their use of shell companies and offshore tax havens and named directors as a way of
disguising who is actually behind the transactions and which countries are actually
involved (Davilas, 2014). The constant evolvement in regulation is matched by a similar
development in criminal behaviour. From a theoretical perspective, this can be identified
as a principal–agent response, as the evolvement or displacement of TBML criminal
behaviour (Souijin, 200148) has largely been determined by the changes in regulation
and how banking risk assessment practice has changed. For example, moving amounts
larger than $10,000 was a red-flag alert in many US banks; therefore, criminals adapted
their practice to make multiple deposits of less than $10,000 to avoid detection.
 This paper has focused on one small but important area, the overlap between TBML Trade based
and the banking sector. Unlike other work that has provided a focus on TBML covering money
all aspects of how it operates and economic predictions on its impact, research is also
needed to support financial institutions in their fight against TBML. Banking research
laundering
needs to focus specifically on the banking context and to be realistic about the limited
financial information that banks are likely to have at any one time for each TBML client.
A focus instead on what banks do well, which is to assess business risk, should still form 523
the basis of the bank’s own business work. AML compliance tasks should fit into this
model of working rather than the other way around, so that AML thinking becomes
incorporated into all aspects of banking operations rather than being seen as a
compliance issue only.

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Further reading
Naheem, M.A. (2015), “Trade based money laundering: exploring the implications for global
banks”, PhD thesis Scheduled for Publication in December 2015.
Naheem, M.A. (2015), “AML compliance – a banking nightmare? The HSBC case study”,
International Journal of Disclosure and Governance. (doi: 10.1057/jdg.2015.5).
Naheem, M.A. (2015), “Trade-based money laundering among biggest banking risks”, Complinet
(Thomson Reuters), available at: www.complinet.com/global/news/news/article.html?
ref⫽177933.

About the author

Mohammed Ahmad Naheem holds a bachelor’s degree and two master’s degrees and has
completed a PhD, all in the economic, banking and investment management domains.
This article has been composed and submitted to the Journal in (December 2014) and has been
adapted from a second doctorate level research project that the author is currently working on
titled “Trade Based Money Laundering: Exploring the Empirical Implications for Global Banks”
which is expected to be published in December 2015.
This current paper contributes towards a series of papers that focus on Trade Based Money
Laundering. Mohammed Ahmad Naheem can be contacted at: mnaheem@sevenfoundation.ch

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