남미의 한 자동차 부품 회사는 실크 꽃 배송에 대한 지불을 참조하여 아시아의 ABC Holdings Ltd.에 매주 여러 번 $500,000 전신 송금을 보냅니다. 조사에 따르면 Sunrise Holdings, Ltd는 소유권 정보가 없는 영국령 버진 아일랜드에 등록되어 있습니다.
이 경우 무역 기반 자금 세탁이 발생할 수 있음을 나타내는 두 가지 위험 신호는 무엇입니까?
(2개를 선택하세요.)
정답: 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
