SBP TBML RED FLAGS IN ALPHABETICAL ORDER

I Just Try To Share SBP TBML RED FLAGS in Alphabetical order....

#TBML #Compliance

A

15 The transaction involves repeatedly amended or frequently extended letters of credit.?

16 An exporter receives advance payment(s) but does not make shipment(s) there against.

D

2 The description of goods on the Goods Declaration Form/Transport documents significantly varies from the description declared on EIF/MIF, EFE/MEF or underlying contract.

14 The transactions involving consecutive trade discount offered by exporters to the same importer.

6 Documents such as a letter of credit is received through unverified channels such as unauthenticated SWIFT message.

22 Where some of the shipping documents are provided in photocopies instead of original against the regularity instructions or against normal business scenarios.

19 The transaction involves import/export of dual use goods

F

18 The transaction appears to involve use of front or shell companies for the purpose of hiding the true parties involved.?

G

23 Where goods declaration in commercial invoice(s) are not proper, incomplete or otherwise not mentioned at all to conceal the facts.

H

11 The country from which goods are being shipped is designated as “high risk” for money laundering activities.

I

4 There are indications that the descriptions of the goods is disguised.?

21 Where important details are missing on commercial invoice(s) or mentioned vaguely.

20 The item ordered is incompatible with the technical level of the country to which it is being shipped, such as semiconductor manufacturing equipment being shipped to a country that has no electronics industry.

17 An Importer remits advance payment(s) but does not receive shipment(s) there against.

7 The type of goods being shipped appears to be inconsistent with the exporter’s or importer’s regular business activities.?

M

13 The method of payment apparently does not commensurate with the risk characteristics of the transaction e.g. the remittance of funds in advance payment for a shipment from a new supplier in a high-risk country.

O

1 Obvious over or under/over pricing of goods (significant discrepancies appear between the value of the goods reported on the invoice/EIF/MIF, EFE/MFE, Advance Payment Voucher and the known fair market value of the goods).?

P

9 The packaging of goods is inconsistent with the commodity or shipping method.

R

24 Receipt of proceeds from non-cooperative countries as per FATF list against the shipment made to a third country.

S

3 Significant variation is found between the description of the goods on the bill of lading and the invoice.

8 The size of the shipment does not commensurate with the size of the exporter’s or importer’s regular business activities.

T

5

The tenor of the transaction does not commensurate with the nature of the underlying goods – for example perishable goods are traded on terms involving lengthy usance period.?

12 The transaction involves the receipt of payments from third parties that have no apparent connection with the transaction.

10 The goods are transshipped through one or more countries/jurisdictions for no apparent economic or logistical reason.

U

25 Where export proceeds are received from unrelated/third party with differing nature of business from that of exporter.