南美洲的一家汽車零件公司每週向亞洲的 ABC Holdings Ltd. 發送多筆 50 萬美元的電匯,參考絲綢花運輸的付款。研究顯示 Sunrise Holdings, Ltd 在英屬維京群島註冊,沒有可用的所有權資訊。
哪兩個危險信號表明在這種情況下可能發生基於貿易的洗錢活動?
(選兩個。)
Correct Answer: A,D
Trade-based money laundering (TBML) is a method of disguising and moving illicit funds through the international trade system. Criminals often manipulate various aspects of trade transactions, such as pricing, quantity, documentation, and commodity type, to transfer value and obscure the source of funds. Some of the common red flags that may indicate TBML are:
* The transaction involves the use of front (or shell) companies: Front or shell companies are entities that have no physical presence, no employees, and no business activity, but are used to facilitate money laundering. They often have vague or generic names, are registered in secrecy jurisdictions, and have no available ownership information. In this case, ABC Holdings Ltd. and Sunrise Holdings Ltd. could be front or shell companies that are used to launder money through trade transactions.
* The type of commodity being shipped appears inconsistent with the exporter or importer's regular business activities: Criminals may use commodities that are unrelated to their core business or that have low correlation with the market price to launder money. They may also use commodities that are difficult to value, verify, or trace, such as precious metals, gems, art, or antiquities. In this case, the automotive parts company and the silk flower supplier seem to have no logical connection, and the value of the silk flowers may be inflated or deflated to transfer funds.
Trade-Based Money Laundering: Risk Indicators - Financial Action Task Force, pp. 9-10, 14-15 Identifying TBML: 8 Trade-Based Money Laundering Red Flags - Alessa, pp. 1-2 FFIEC BSA/AML Appendices - Appendix F - Money Laundering and Terrorist Financing Red Flags, p. 7 AML Red Flags - What are the Top 10 Indicators? - ComplyAdvantage, p. 1