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The US government requested better coordination of trade-based money laundering

The US Government Accountability Office (GAO), which conducts audits of the government at the request of elected representatives, reported on December 13 that it recommended that the US Department of Homeland Security allow greater sharing of data from the country’s Trade Transparency Units, (TTU), and the US Department of Homeland Security.

To help detect suspicious trade transactions, the TTU collects financial data and custom data from the US.

GAO found that the TTU “is… missing opportunities to better analyse and distribute information from US customs data which could aid enforcement and investigative agencies in identifying suspicious activities.”
Trade-based money laundering is often committed by over- or under-invoicing. Reports indicate that banks don’t always have access the underlying trade documents for open-account trading and cannot keep up with all goods’ true market value.

Global Financial Integrity, a US think tank, recently estimated that invoicing errors between developing countries and their trading partners were worth US$1.6tn.

According to the watchdog, without having access to TTU’s data, law enforcement officers and government agencies involved in investigating and understanding trade based money laundering won’t be able identify emerging risks and detect illicit schemes.

GTR reached out the Department of Homeland Security to get comments, but they didn’t respond. GAO was informed by the Department of Homeland Security that it didn’t agree with the recommendation not to further spread TTU data. The Department of Homeland Security stated that the US Immigration and Customs Enforcement was committed to using their legal authority to investigate and fight trade-based money laundering and smuggling and other criminal acts within the jurisdictional reach Homeland Security investigations.

GAO believes that the department may have misunderstood the report. GAO notes that the US government believes it is limited in its ability share data with international partners via information-sharing agreements.

According to the GAO ICE is currently working on a strategy plan to “guide efforts in increasing collaboration with partner countries to fight trade-based cash launder and to identify a strategy for guiding the growth TTU international partnership”.

To facilitate information sharing and analysis between government agencies, as well as private sector companies, the US Treasury should create an “interagency collaboration mechanism”.

GTR requested comments from Treasury Department. However, they informed the authors of the report about the necessity of allowing more trade data to be made available by the Department of Homeland Security to improve coordination between the different government branches.

The GAO was asked by four senators, three Republicans and one Democrat to examine the government’s coordination. They asked that the GAO examine the government’s 2018 approach to combating trade-based money laundering.

GAO reports from February 2020 and June 2020 showed that money laundering via these crimes amounts to large amounts and is increasing. GAO reports also revealed that TTU models do not work due to lack of funding or follow-up in certain countries.



Sheldon Whitehouse was among the senators who requested this report. He responded that “kleptocrats, drug traffickers” rely on sophisticated trade-money laundering schemes to hide their illicit gains. Our law enforcement professionals, the private sectors, and global partners must all work together to combat this.

Marco Rubio, another senator requested the GAO Report. He stated that criminal organizations continue to illegally profit from money laundering. The GAO Report is welcome so that legislators can respond more effectively to these nefarious organisations.

“It is vital that US agencies cooperate to reduce this criminal activity. My colleagues and I look forward working together to combat trade-based money laundering.
A trillion dollar problem: Mis Invoicing

Global Financial Integrity (GFI), a think tank in America, released a report last week indicating that the criminal gains from misinvoicing global trade has surpassed US$1tn per year since 2010. The highest point was reached in 2018, when it had sufficient data to analyze.




The group, which studies and makes recommendations on policy regarding financial crime, came up with the figure by adding up the exports each country made to another country and the receipts claimed to have received.

GFI stated that although there are reasons to expect some discrepancy in the reported international trade data for any two countries in a given year, it believes that the majority of these figures are indicative of trade invoice activity.

According to the study, China had the largest trade deficits of all the 136 countries that were surveyed, with a US$305bn gap in value. The next were India, Russia and Malaysia.

GFI estimates that mis-invoicing is causing some developing countries to lose substantial customs revenue or taxes. GFI conducted a survey of 170 countries to find that The Gambia had an average value gap of 45%. This was the largest gap among all the developing nations.

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