Guidelines for Prevention of Trade Based Money Laundering

Bangladesh Financial Intelligence Unit • Bangladesh Bank • 2019

Learning purpose: This portal converts the BFIU guideline into a practical bank-learning deck for trade operations, AD branches, OBUs, compliance, audit, risk teams and training sessions.
Core riskDisguising criminal proceeds and moving value through trade transactions.
Control modelInfrastructure, customer, transaction and enterprise-level TBML risk assessment.
Operational engineThree-level review system supported by TTP, alerts, screening, price verification and STR/SAR process.
ItemContent
IssuerBangladesh Financial Intelligence Unit, Bangladesh Bank.
DocumentGuidelines for Prevention of Trade Based Money Laundering, 2019.
Legal basis referredMoney Laundering Prevention Act, 2012; Money Laundering Prevention Rules, 2019; Anti-Terrorism Act, 2009; FERA 1947; Customs Act, 1969; Import and Export Control Act, 1950; IPO/Export Policy and regulator instructions.
ApplicabilityAll scheduled banks, AD branches, OBUs and any branch/unit/division engaged in trade-related activities.
Products coveredDocumentary credits, guarantees, SBLCs, collections, open account, cash in advance, trade finance/payments, services and software trade.
Important learning note: Alerts are indicative and non-exhaustive. Banks should update TBML alerts and controls based on their own risk exposure, typologies, regulator instructions and transaction experience.

Guideline Map

Chapter 1: Introduction

This chapter explains why TBML/TF matters, which banks/units and products are covered, and who should be considered in trade due diligence.

Chapter 2: Landscape of TBML in Bangladesh

This chapter translates Bangladesh-specific vulnerabilities into practical bank risk points for import, export, royalty/service fee, OBU and specialized zone transactions.

Chapter 3: Risk Based Approach and TBML Controls

This chapter is the operating model: infrastructure, customer risk assessment, transaction review, enterprise risk management, STR/SAR and training.
Infrastructure Risk Assessment
Customer Level Risk Assessment
Transaction Level 3-Stage Review
Enterprise Level Risk Management

Three-Level Review System

Depending on risk, transactions should be disambiguated at Level 1 or escalated to Level 2/Level 3 before execution, rejection or STR/SAR reporting.
LevelTypical officialsMain responsibilityDecision output
Level 1Maker, checker, authorizer, reviewer, verifier or designated trade processor.Check KYC/TTP, perform TBML alert analysis and sanction screening, execute or escalate.Process transaction, escalate to Level 2, or raise suspicion.
Level 2Trade compliance officer, head of trade or designated senior officials.Review Level 1 alerts, consult TTP, use third-party data, disambiguate or escalate.Instruct Level 1 to process, reject/escalate, or send to Level 3.
Level 3DCAMLCO or CAMLCO-assigned officials with strong TBML expertise.Comprehensive review, decide if alerts are mitigated or suspicious, file STR/SAR where required.Process, reject, post-facto scrutinize or file STR/SAR.

Practical Escalation Logic

StepQuestionAction
1Is there a current approved KYC and TTP?If no, stop and complete customer-level requirements.
2Any sanction hit or TBML alert?If false match/mitigated, document rationale. If unresolved, escalate.
3Can Level 2 disambiguate with evidence?If yes, process with documented rationale. If no, send to Level 3.
4Does suspicion remain after Level 3 review?Reject/process as decided and file STR/SAR where required.

TBML Alerts

The guideline provides non-exhaustive alert indicators. This deck groups major alert themes for easier learning and operational use.

Bangladesh Case Lessons

Appendix A provides Bangladesh-context abuse examples. The learning point is not to memorize cases, but to recognize recurring risk patterns.

Appendices and Annexure Summary

SectionPurposeNow added as separate slide tab
Appendix ASome instances of abuse of trade in Bangladesh context.Appendix A: Abuse Cases
Appendix BTBML Alerts.Appendix B: TBML Alerts
Appendix CProduct-wise TBML alerts, relevant lists and examples.Appendix C: Product-wise Alerts
AnnexureTrade data and brief analysis.Annexure: Trade Data
Use in training: Pair each alert with at least one case example and ask trainees to identify Level 1, Level 2 and Level 3 actions. The full appendix and annexure content is now available in separate slide tabs immediately after this summary.

Appendix A: Some instances of abuse of trade in Bangladesh context

Correct-format source content: The content below is added from the uploaded guideline as separate page-wise slides to avoid missing appendix/annexure material. Use the slide buttons to move through the full section.

Appendix A: Some instances of abuse of trade in Bangladesh context — Slide 1 PDF page 43

   Appendix A: Some instances of abuse of trade in Bangladesh
                           context
(Lessons should be learnt from related large scams published in various media, the case
studies published in the BFIU annual reports and other relevant sources as well)


Case 1: TBML through bill of entry fabrication
Mr. ‘P’, an importer, opens an LC amounting USD 7, 58,710.30 for import of edible oil.
Bank made payment of the full amount (USD 7,58,710.30) based on shipping documents and
endorsed the same in favor of the importer for the purpose of releasing the goods. Instead of
those documents, a set of fabricated documents were submitted to the customs as the value of
goods arrived under that LC was only USD 54,150.00. However, goods could not be released
from customs due to failure in quality inspection. Meanwhile, a fabricated copy of bill of
entry valuing USD 7,58,710.30 was submitted to the bank evidencing the proper release of
the goods. When the fabrication was revealed by Bangladesh Bank, explanation was called
and subsequently the remitted amount (USD 7, 58,710.30) was returned from two different
countries other than the beneficiary's country and no evident relation was found with the
beneficiary regarding this refund.
TBML Alerts:
   1. Inadequate assessment of trade customer.
   2. Refund from third countries not related to beneficiary.
   3. Supplier country was not the producer of the goods.
   4. Shipping documents not verified.
   5. Bill of Entry not verified by the bank.
   6. Though large amount, adequate cautionary measures were not taken.

Case 2: TBML through releasing high value goods using copy documents
Mr. ‘M’, an importer of trading goods, opened two LCs worth USD 12,180 and 5,240 during
August 2016 at a Bangladeshi commercial bank for importing Tyres and released the goods
from Customs against the second LC using copy documents. Bank was informed by the
importer that goods against the other LC were under process of release. No import payments
were made due to non-receipt of original shipping documents. Due to non receipt of the
payment, complaint was lodged by the beneficiary with necessary documents. The LCs as
referred to by the complaint of non-payment was for USD 6, 39, 478 and was not issued by
any Bangladeshi bank, rather it was issued by a finance company of a western country during
June 2016. However, analysis reveals that in addition to the LC opened at the western
country the two commercial invoices also refer LCs issued by the Bangladeshi bank; and the
name, address, IRC and BIN mentioned in the two invoices completely match with the



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information in OIMS. Moreover, name and quantity of the goods as mentioned in the
invoices also bear similarity with the ones mentioned in the Bill of Entry.
Therefore, it appears that the LC issued in the western country has connection with the LCs
issued by the Bangladeshi commercial bank. In collusion with the exporter, the importer
perhaps wanted to avoid tax opening LCs of lower value and releasing goods through copy
documents. As the breach of trust between importer and exporter occurred and the exporter
didn’t receive payment, complaint was lodged and the incidence came to light.
TBML Alerts:
   1. Inadequate assessment of trade customer.
   2. Probable collusion between importer and exporter.
   3. Issuamce of LC by a finance company from third country.
   4. Proper due diligence in value and unit price verification of the goods was not
      conducted.


Case-3: TBML through phantom shipment
Mr. ‘F’, an importer of fruits, usually operates with ‘P Bank’ with small scale LCs. All on a
sudden, he opened account with three other banks and at a time opened 21 LCs with the four
banks worth USD 9,106,842.50. Banks made import payments based on shipping documents.
No single shipment was made against the LCs and the amounts remitted were not refunded.
TBML Alerts:
   1. Lack of proper due diligence for the customer by the three banks.
   2. Vessel container was not tracked.
   3. Number and value of LC inconsistent with customer’s bsiness pattern.

Case-4: TBML through import of old/used capital machinery
Mr. ‘M’ opened a usance LC to import old/used capital machinery for around USD 16,000.00
in 2016. Within one month and a half shipment was made and documents were received by
the bank. Though initially discrepancy was established under UCP 600, payment was made
by the bank. While releasing machine from Customs, it was found that the minimum
economic life exceeds the limit permitted in current IPO and the certifying authority was not
nominated by NBR. Goods were confiscated by Customs. Meanwhile, import payments were
made and the machineries were placed for public auction by the Customs.
TBML Alerts:
   1. Import involved high risk goods.
   2. Certifying authority was not nominated by NBR.
   3. Importer and exporter were somehow related parties.



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   4. Old/used machinery import rules and regulations were violated by the bank and the
      importer.


Case-5: TBML through importing different goods
Mr. ‘Z’, a new importer opened an LC for importing malt beverage (lower duties and taxes)
from Singapore worth USD 5,460. Goods were shipped and shipping documents were
received by the bank. Upon instigation of the importer, bank official raised a minor
discrepancy and held the documents. Meanwhile, Customs imposed higher taxes and duties
on the goods while releasing those as it was revealed that the goods were light-alcoholic beer.
Consequently, customer refused to take the goods. Goods were confiscated and placed for
public auction by Customs. The highest bidder who got the auctioned goods was the agent of
the importer. Thus, importer released the goods, sold it in the market and then informed the
bank of his readiness to accept the discrepant documents. Therefore, bank made the import
payments. In this way, Customs lost the applicable taxes and probably the rest of the prices of
the light-alcoholic beer was suspected to be paid through informal channel.
TBML Alerts:
   1. Misrepresentation of goods for duty and tax evasion purpose.
   2. Importer behaviour to raise discrepancy in the beginning and afterwards his readiness
      to receive discrepant documents.

Case 6: TBML attempted at first through sea port then through land port
An attempt was made to remit more than USD 4,27,500 submitting forged documents such as
No Objection Certificate of a commercial bank in Bangladesh and that of a western country
at a land custom house. A transferrable LC opened in January, 2018 at the bank of a western
country mentions import of 500 MT of onion at the rate of 855 USD (per MT). The
Bangladeshi commercial bank’s NOC showed a signature of branch manager and another
signature of President & CEO & CFO while foreign bank’s NOC showed one signature of
CFO and another signature of President & CEO & CFO. However, Bangladeshi commercial
bank branch didn’t have official of such rank. When the Customs official took step to verify,
this illegal attempt ended in vain. Matter of concern is that the consignee of the goods was a
customer of that commercial bank in Bangladesh.
TBML Alerts:
   1. Lack of adequate KYC and verification of trade customers by the bank in such
      situations.
   2. Immediate steps have to be taken after getting the verification notices in such
      circumstances.
   3. All ADs, Customs and relevant agencies should be informed immediately after such
      incidences.


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Case 7: SWIFT password was hacked from back office and used to make fraudulent
payment
SWIFT password was hacked and payment instruction was made to the Nostro A/C to pay
USD for the payment against import. Consequently payment was made and statement was
sent to back office accordingly. But back office did not scrutinize and the middle office also
didn’t reconcile with the requisition from the branch to pay USD against import
payment.Next day another instruction was made to pay GBP but GBP was not available in
the Nostro A/C. Treasury Management Department (TMD) was asked to place GBP to the
nostro account of GBP but TMD had no requisition in support with the instruction. TMD
asked the Nostro A/C to stop the payment. USD payment had already been executed and it
was not possible to recover the amount.
TBML Alerts:
   1) SWIFT message did not mention underlying transaction reference.
   2) Lack of checking by back office and no reconciliation by middle office.
   3) Rationale behind payment instruction was not verified.

Case 8: Guarantees converted into funded liabilities
Exporter received contract from a European country for export of vassel and received
advances in various installments from the importer. Advance payment guarantee and
performance guarantee were issued by the exporter’s bank. Counter guarantees were issued
by another foreign bank. Exports were not executed within the stipulated time and contracts
were cancelled. Consequently guarantees were encashed by the foreign bank. Local bank
created forced loan to pay guarantee amount with interest. The client i.e. the exporter failed to
pay the amount and the loan converted to term loan and finally turned into Non Performing
Loans.
TBML Alerts:
   1) End use of advanced receipt against prospective Export was not monitored and
      confirmed by the bank.
   2) Performance of the exporter was not assessed accurately.

Case 9: TBML through import & export using related parties
Company ‘X’ in Bangladesh is owned by an Influential Person (IP). This company has been
awarded a government project to install a power plant for which they opened LC favoring a
beneficiary company ‘Y’ located in Singapore to import capital machineries, spare parts and
accessories of BDT 2 billion. Accordingly, the Company ‘X’ made payment against the said
LC.




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Another company ‘Z’ in Bangladesh has a sale contract with company ‘Y’ in Singapore to
export agro product to India for BDT 1 billion. Export proceeds are received by company ‘Z’
from company ‘Y’ in Singapore through another bank in Bangladesh though goods are
shipped to India. This company ‘Z’ has received cash incentive of BDT 0.2 billion (@20%)
from the Government against export of the agro-products. Company ‘Z’ is newly registered
as an exporter and obtained ERC from the CCI&E. Finings show that Company ‘Y’ in
Singapore is an affiliate company of company ‘X’ and the owner of company ‘X’ is also a
partner of company ‘Z’. Export price of agro product in documents is unusually high and the
quantity exported is under-shipped. Thus the government money is embezzled through trade
transactions.
TBML Alerts:
   1) Transaction is not in line with customer’s Trade Transaction Profile (TTP) or line of
      business.
   2) Importer and exporter are related parties and there is common interest.
   3) Over Invoicing and Under Shipment against agro product export to India.
   4) Goods shipped from Bangladesh to India but importer is located in Singapore.


Case 10: TBML through trade fraud by supplier
Company ‘ABC’ in Bangladesh availed an LC to import capital machinery from Switzerland
for USD 50,000.00. LC was confirmed by a foreign bank in Bangladesh. Presenting
documents beneficiary claimed payment from confirming bank (CB). CB honored the claim
of beneficiary and placed claim to issuing bank in Bangladesh. Issuing bank paid by creating
a Loan against Trust Receipt. After few days of payment importer lodged a claim to the
issuing bank that goods received by them is not the desired goods, rather they are old
spoiled machineries. Meanwhile, after receiving the money beneficiary closed their account
in the Swiss bank. Applicant filed a case in the court in Bangladesh. An analysis showed that
though it was regulatory obligatins to obtain supplier’s credit report, issuing bank as well as
the confirming bank did not obtain it before opening and confirming LC. Applicant
complained against the bank that the loss incurred due to banks’ failure to obtain supplier’s
credit report before opening LC. As such they claimed that banks should bear the loss since
they would not be able to repay the import loan.
TBML Alerts:
   1) Supplier’s credit report was not obtained.
   2) Supplier’s line of business was unknown.
   3) Payment term was favorable to beneficiary with less protection to applicant.
   4) Importer and exporter may be related parties with common interest.




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Case 11: TBML by sending fund to importing country through hundi and repatriating
as export proceeds while transferring original export proceeds to a third country
‘ABC’ is a pharmaceutical finished goods exporter of Bangladesh. This company mainly
generates its revenue from domestic sale and hardly exports in countries like India, Pakistan
and UAE. Most of its export is based on sales contract and mode of payment is 90 days
deferred from shipment date. It uses multiple banks as nominated bank but the transaction
volume is low. 3 different banks issued EXPs favoring this exporter for exporting finished
productes to India, Pakistan and UAE against diferent contracts. After shipment to 3 different
countries, exporter submits export bill in 3 different EXP issuing banks. After ninety 90 days
payment is received from Pakistan only but the other EXPs become overdue after 120 days
from shipment. It is revealed afterwards that exporter contacts with Hundi businessmen to
send money from Bangladesh to India. Indian Hundi counterpart deposits fund into banking
channel using dishonest businessmen. Indian importer sends export proceeds from their
banking channel to ABC co.’s exporting bank. Export proceeds are received through MT103
instead of MT202 message in the name of exporter without mentioning export bill reference.
Exporter submits the request letter to realize the proceeds against the overdue export bill and
thus EXP overdue becomes regular. This fund is also used to convert it as export proceeds for
shipment to UAE. Goods shipped to India and UAE are sold to that local market and sales
proceeds are transferred to an offshore hub.
TBML Alerts:
   1) Export proceeds received through MT103 instead of MT202.
   2) Swift message does not mention the underlying transaction reference number.
   3) Payment received from third country.

Case 12: TBML through import LC issuance and import payment
‘ABC’ is a very reputed and leading company in Bangladesh in computer and accessories.
This company has multiple joint ventures in countries like Singapore, Malaysia, Hong Kong,
China, China and India. They are also involved in providing financial services and have some
trust operations in Cayman Island. This company (non EPZ in nature) is also dominant in
Bangladesh with good reputation as conglomerate and their business slogan is ‘Customer is
first’. They are willing to pay higher fees if same day payment is guaranteed. The company
imports different types of computers, parts and accessories from different countries of the
world. They have both industrial and commercial IRCs. ‘ABC’ company requested their bank
‘X’ to issue one import LC favoring beneficiary in Singapore. PI indicates import LC value is
$1,000,000.00 consisting of import of computor monitor, keyboard and other accessories.
They prefer ‘X’ bank as it makes payment very quickly after receiving import documents and
customer always likes to pre accept the discrepancy. Customer also wants to avail UPAS
benefit as this import is industrial in nature. Though customer opens LC under industrial IRC,
their underlying purpose is to sell the imported items commercially. Conducting due


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diligence, bank issues import LC and receives import bill later on. While lodging import bill,
bank official finds that some of the items are not available in PI but these are included in CI.
When asked by bank, importer confirms that they import product on demand and schedule is
very tight. In addition, computer technology is ever changing element. Hence during
shipment they changed some of the items with change in unit price. When bank official wants
to take more time for scrutiny, customer becomes unhappy about the service and threatens to
move business to other banks. Customer also confirmed that their counterpart in Singapore
wants payment copy by the same day. Considering charges, commission and other incomes,
the size of business and customer pressure, bank processes the bill and makes payment.Thus
importing inferior quality goods and over invoicing leads to TBML.
TBML Alerts:
   1) Customer is very keen to waive discrepancy and make quick payment.
   2) Customer is not concerned about charges.
   3) Customer always expresses his acceptance on import documents before receiving
      import bill.
   4) Avails UPAS benefit under industrial LC for commercial purpose.
   5) Trust in Cayman Island may be owned by both importer and exporter.

Case 13: Involvement of third party (unrelated party) for layering and integration via
buying house commission
‘X’ is a very reputed and leading company in Bangladesh for garments manufacturing items
and accessories. This non EPZ company has multiple joint ventures in countries like
Singapore, Malaysia, Hong Kong China, China and India. They are also involved in financial
business and have some trust operations in British Virgin Islands. They conduct banking with
couple of prominent banks in Bangladesh. Company ‘X’ imports different raw materials from
different countries and exports finished goods to prominent market like US, EU etc. and
enjoys bonded warehouse facility for import for industrial consumption. On one occasion ‘X’
imports cotton from Uzbekistan, Zimbabwe through Singapore for USD 75,000.00 keeping
master export LC of USD 100,000.00 as lien. 3 months later, exporter submits export bill for
USD 100,000.00 with the additional instruction to the negotiating bank that 40% export
payment will be paid to the buying house/commission locally as commission which is
transferrable from ERQ account. When asked about the excessive commission, exporter
replies to the negotiating bank that the quality of goods is inferior in nature and outdated.
Convinced with the response, negotiating bank processes the export bill. Buying house
receives the fund with legitimacy and thus underlying commission is used to perpetrate
money laundering.
TBML Alerts:
   1) Imports from landlocked countries which are risky for terrorism and sanctions.



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   2) Use of bonded warehouse facility for tax evasion.
   3) Lack of verification and understanding of the quality of the goods.
   4) Excessive commission.


Case 14: TBML through over invoicing
M/s. ‘R’ Enterprise, a client of ‘X’ Bank branch, located in border area, deals in import and
export business. Besides, the client also deals with the cattle business from India to
Bangladesh. The client usually imports onion from India. M/s. ‘R’ Enterprise approaches ‘X’
branch to avail an LC valued USD 60,000 for importing 100 Metric Ton onion from India
favoring M/s. ‘D’ Enterprise. ‘X’ branch issues the LC in favor of M/s. ‘D’ Enterprise, India.
M/s. ‘R’ Enterprise receives the goods and sells in the market duly and payment is made
accordingly. But it is observed that it sells TK. 25000/- per Metric Ton in the open market
while the total import cost per Metric Ton onion is of BDT. 50,000/-. Later M/s. ‘D’
Enterprise makes cross border smuggling of 30 cattle from India to Bangladesh. M/s. ‘R’
Enterprise receives the cattle, sells them in the market and gets illicit proceeds.
TBML Alerts:
   1) Over invoicing.
   2) Illegal cross border.

Case 15: TBML by two brothers through different methods
Mr. ‘X’, an expatriate from Chapainawabganj District lives in Dubai, UAE with free visa. He
operates a grocery shop in Dubai. His younger brother ‘Y’, credit client of branch ‘A’ deals
in paddy, rice and cattle business and works as an agent of his elder brother. ‘X’ convinces
the Bangladeshi expatriates visiting his shop to send their money to Bangladesh through him
providing 1 or 2 percent higher rate than banking channel with the surety of making payment
to him after confirmation of receiving money by their beneficiaries in Bangladesh either in
account or in cash. When the expatriates agree, he directs his younger brother ‘Y’ to deliver
money to the respective beneficiaries’ bank accounts or in cash. Upon confirmation of
receiving money by their beneficiaries, the expatriates pay money to ‘X’. In the mean time,
‘Y’ gets bank’s credit showing different purposes or earns money from illicit sources and
with that money he pays to the beneficiaries in Bangladesh. ‘X’ with that money buys gold
and diamond ornament, gold bar having great demand in Bangladesh for the belief of their
purity. Usually he sends gold and diamond ornament through the agent under Bangladesh
Customs baggage rules. ‘Y’ receives such gold and diamond ornament, gold bar and sells
them in the open market. With that money, he adjusts bank dues against credit and buys real
estate in his own and his brother’s name.




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TBML Alerts:
   1) The remittance is coming from UAE through Alternative Remittance System and the
      perpetrator takes credit from a local bank to disburse the money to the local
      beneficiary.
   2) The colluder partners engaged in a valid trade cycle under Customs baggage rules.

Case study 16: TBML through Offshore Banking Unit
A Singapore based fund-raising and investment company named ‘A’ approaches a reputed
bank in Bangladesh named ‘X’ seeking loan of USD 20.00 million. The company ‘A’ is
registered in Singapore to conduct its operations as a financial organization. But the license is
cancelled, thereby turning the fake company fully invalid.
‘A’ submits an ordinary application to borrow fund from ‘X’ Bank in Bangladesh in collusion
with Bank’s high officials and Board members. ‘A’ does not submit any Articles of
Association, Business Profile, Registration Certificate and Memorandum of Article of
Association along with its application. Mr. ‘B’, a Canadian citizen, is a director of company
‘A’ and signs the loan application on behalf of ‘A’.
The ‘X’ Bank signs the deal with ‘A’ to invest USD 20 million on condition that ‘A’ would
give return of 8% interest on the loan. ‘A’ also promises of investing USD 80 million with
the Bank within 95 days of getting loan USD 20 million.
‘A’ creates a subsidiary company named ‘C’ in Dubai to act as Special Purpose Vehicle
(SPV) to transfer the borrowed fund. To work as SPV, it is obligatory to be a financial
Institution or an investment company but ‘C’ is a trading company. ‘C’ opens an account in
UAE based ‘Y’ Bank. The account with ‘Y’ Bank is supposed to be jointly controlled by ‘A’
and ‘X’ Bank as per loan agreement. But actually this does not happen.
Later, it is found that the Chairman of ‘X’ Bank is the nominee of Bank’s fund e.g., USD 20
million and a joint signatory of the account maintained with ‘Y’ bank in Dubai.
‘X’ Bank finally remits the USD 20 million funds to ‘Y’ Bank. Later on fund cannot be
traced. It is noted that since ‘X’ Bank does not have foreign currency, it buys USD with BDT
from interbank money market in Dhaka with higher price. Just after remitting the fund‘C’
withdraws the total fund and closes the account maintained with ‘Y’ Bank.
TBML Alerts:
   1. Investment abroad manipulating OBU loans and ultimately leading to money
   laundering.
   2. Failure of OBU to take legal advice from both local and foreign law firm before
   investing abroad.
   3. Failure to comply with regulatory rules in OBU fund management.




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Case study 17: TBML through fake documents
Mr ‘X’, proprietor of ‘A Food Products’ opened 3 current accounts in 3 branches of 3
different banks. The account opening form used the official address in Banani, Dhaka and
factory address in Salna, Gazipur. The customer was willing to export turmeric, pepper
powder spices but no proof regarding the export capacity or previous business experience of
the customer was preserved.
A foreign buyer located in Dubai named ‘M/s. B Trading LLC’, Dubai, remitted USD
15,98,545.00 favoring the account of ‘A Food Products’ through an exchange house named
‘Y Exchange Center LLC’, Dubai, UAE using 26 Advanced FTTs. Out of this 26 Advanced
FTTs, 10 FTTs amounting USD 6,08,035.00 were shown as export proceeds of turmeric,
pepper powder spices. 20% cash incentive was claimed by the exporter and bank authorities
reclaiming the same amount from Bangladesh Bank credited BDT 98, 15, 689.00 to the party
account. Rest of the 16 FTTs had no export documents preserved in the branches. These
remittances were not reported to Bangladesh Bank by the AD branches. The entire amount
was encashed through the current accounts of the customer. During inspection it was found
that all the export documents were fake. Forged bills of lading were prepared using the letter
head pad of a foreign shipping company and seal and signature of its local shipping agent. All
these were used to prepare forged export documents and claim cash incentive by the
customer. The inspection team communicated with the local agent of the bill of lading issuer.
The shipping agent by a letter informed the Bangladesh Bank as well as the commercial
banks that the exported goods against which cash incentive was claimed were not shipped by
them, rather the exporter used fake seal and name of the shipping agent. Upon receiving such
letter from the said shipping agent, Bangladesh Bank directed the banks to realize the said
cash incentive amount from the customer.
TBML Alerts:
   1) The customer engages in transactions that are inconsistent with his business strategy
      or profile.
   2) Amount of foreign currency transacted through exchange house is abnormal and
      doesn’t match with the reality.
   3) Essential documents not presented/obtained and verified properly.

Case study 18: TBML through back-to-back LC
A UK based buyer, ‘XYZ Ltd’. placed export order through sales contract by two local
garment buying houses named ‘A’ and ‘B’ Apparels Ltd. The foreign buyer lured the
Bangladeshi exporters invoicing higher price per unit of export goods. In exchange the buyer
put conditions to procure high priced raw materials from its nominated suppliers based in
China.




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Receiving the sales contract, Bangladeshi exporters opened back to back letter of credit (BTB
LC) in order to procure raw materials. After the shipment of several consignments these
exporters came to know that the foreign buyer ‘XYZ Ltd’. did not receive the exported
garments. The exported goods were left unattended in the Manchester port and exporters
were bearing higher rental cost for the containers. At that time Bangladeshi garment exporters
could understand that they had fallen victim to fraudulence. In the name of BTB LC money
was siphoned off from the country, but export proceeds could not be repatriated. During BB
inspection it was observed that banks did not take ratings and information of the credit
reports of the foreign buyer and supplier into consideration. It was also revealed that one
director of ‘XYZ Ltd.’ was Chinese. This director may have linkage with or may be one of
the suppliers in China. Banks also did not justify the market price of raw materials though
unit price of raw materials was very high. In the meantime, the Chinese suppliers started
knocking Bangladesh Bank for settlement of BTB LCs. Some banks already paid and some
held the documents as discrepant.
TBML Alerts:
   1) Buyer nominated supplier.
   2) Credit Report of buyer and the supplier was not taken, and in some cases report was
      taken but was not analysed properly.
   3) The price is unusual.
   4) Probable collusion between buyer and supplier of raw materials.

Case study 19: TBML through fraud
During an inspection by Bangladesh Bank on a private commercial bank branch, it was
observed that the bank branch was intentionally hiding the overdue export bill as well as
overdue EXPs. As a result the customer could continue to avail the facilities like cash
incentive, EDF loan, BIDA approved low cost foreign loan. It is challenging to find out those
hidden overdue export bills among thousands of EXPs. But during inspection it was found
that five customers were given cash incentive even though they had overdue export bills. The
amount of cash incentive disbursed through this malpractice was more than BDT 300 million.
The bank was instructed to immediately return the cash incentive amount disbursed violating
Bangladesh Bank regulations and take necessary action against the responsible officials.
TBML Alerts:
   1) Wilful non-reporting of overdue export bills.
   2) Cash incentives allowed to customer not eligible as per regulations.
   3) Advanced cash incentives allowed.




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Case 20: TBML through purchase of foreign documentary bills
During inspection by Bangladesh Bank on a commercial bank branch it was observed that
several customers were exporting leather goods to foreign countries. The largest portion of
the loan portfolio of the bank branch was composed of Foreign Documentary Bill Purchase
(FDBP). Most of the export bills of leather goods were of 90 days deferred LC term. But the
branch was found to provide 120 days tenor to hide the number of overdue export bill. The
branch not only exaggerated the tenor of the export bill but also purchased those bills without
receiving the acceptance from the LC issuing bank. The branch was already exposed to
greater risks by purchasing export bills without acceptance. Moreover, it continued
purchasing the bills of the customer who already had overdue export bill. During further
analysis it was found that four of the export companies had the same owner. The motive was
to simplify the process of purchasing more bills on account of a customer if others fall
overdue.
TBML Alerts:
   1. Wilful non-reporting of overdue export bills.
   2. Allowing longer term trade financing.
   3. Purchasing bills without acceptance from the LC issuing bank.
   4. Purchasing bills of the customer who already had overdue export bill.




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Appendix B: TBML Alerts

Correct-format source content: The content below is added from the uploaded guideline as separate page-wise slides to avoid missing appendix/annexure material. Use the slide buttons to move through the full section.

Appendix B: TBML Alerts — Slide 1 PDF page 55

                           Appendix B: TBML Alerts
TBML Alert, a warning sign, is not in itself an indication that something is wrong but that
given the nature of the client’s business and the nature of the underlying transaction, the
TBML Alert merits further review.
The TBML Alerts may be sub-divided into the following categories, i.e.
              a. The transactions
              b. The goods and size of shipment
              c. Transport
              d. Payment
              e. Country
              f. Party/parties
              g. Discrepancies
              h. Unusual documentation
Banks should take into consideration the TBML Alerts described below while conducting
trade operations:
   TBML
                        TBML Alerts                  Purpose/Rationale with example
  Aler No.
                                    Applicant/Beneficiary
 Alert# 1     Importer and exporter are          In most cases of illegally transferred
              related parties and there is       fund, applicant and beneficiary are
              common interest.                   related or connected parties or there are
                                                 some common interests between them.
                                                 So bank needs to be aware of whether the
                                                 applicant and beneficiary of a trade
                                                 transaction are in any way related to
                                                 some common interests. In this context,
                                                 bank should also follow instructions
                                                 contained in para 2 of Chapter 7 and para
                                                 7(b)(iv) & para 7(c) of Chapter 8 of
                                                 GFET, 2018.

Alert# 2     Transacting parties appear to be     Party ‘A’ enters into a contract with party
             affiliated, conduct business out     ‘B’ for import of goods through
             of a residential address or          documentary credit. The contact address
             provide only a registered agent’s    of party ‘B’ appears C/O: legal
             address.                             representative name and its address
                                                  details, or prior to opening of LC, credit
                                                  report of party ‘B’ reveals that party B’s



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                                                     line of business is not consistent with
                                                     underlying goods. In both instances, the
                                                     exporter may try to hide the true
                                                     beneficial owner of the transaction.

Alert# 3       Customer behaviour.                   The behaviour of the customer may give
                                                     rise to TBML alerts. For example, the
                                                     customer suddenly becomes anxious and
                                                     puts pressure on the bank, or offers
                                                     bribery, threatens to terminate business
                                                     relationship to execute the transaction.

Alert# 4       Any of LC/Contract/Guarantee         PEPs & IPs may exert undue influence to
               parties are known to be owned        conduct trade transaction in their favour.
               or controlled by Politically         As such banks need to have an effective
               Exposed Persons (PEPs) or            mechanism to identify PEPs’ involvement
               Influential Persons (IPs).           in the trade transactions as applicant or
                                                    beneficiary or any other party.
                                        3rd Parties
Alert # 5      Involvement of the parties in       It has been seen that applicant and
               the trade transaction cannot be     beneficiary are not willing to explain the
               explained.                          rationale      of     involvement       of
                                                   intermediaries in the transaction. At this
                                                   backdrop, though banks may not be able
                                                   to know all the parties involved in the
                                                   transaction, they should understand why
                                                   they are involved, and involved parties
                                                   with no apparent logical role in the
                                                   transaction should be examined further.
Illustration   Party ‘A’ approaches Bank ‘B’ to open an LC favouring beneficiary of country
               ‘C’. Party ‘A’ requests bank to advise the LC in any bank in Country ‘D’
               instead of country ‘C’. However, there is no information in proforma invoice on
               the basis of which the reason of such demand by the beneficiary can be
               ascertained. In addition to that the beneficiary further demands credit available
               in another country not related to beneficiary’s country. This type of scenario
               needs further analysis in order to understand different parties’ involvement in
               the transaction.

Alert # 6      Too many intermediaries              An applicant or beneficiary may approach
               making transaction overly            a bank for a trade transaction with too
               complex.                             many intermediaries involved in the



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                                                      transaction with an ill motive of executing
                                                      transaction through creating complexity.
                                                      As part of due diligence bank should
                                                      understand      the      justification   of
                                                      involvement of intermediaries within the
                                                      trade cycle. Contact from unexplained
                                                      parties may be an indicator of a
                                                      transaction that is more complex than it
                                                      appears or an indication of unusual
                                                      activity.

                                      The transactions
Alert# 7       Transaction structure appears     Though financially solvent, the applicant
               unnecessarily complex or          may avail trade finance facility from the
               unusual and designed to obscure bank in order to disguise the true nature
               the true nature of the            of the transaction. He may use unusual
               transaction.                      trade term, involve many countries &
                                                 intermediaries in the transactions.
                                                       Hence, as part of process banks should
                                                       review the structure and complexity of an
                                                       LC/Contract.
                                                       Banks should analyse financial products
                                                       and transaction structures and determine
                                                       if they are intended to obscure the true
                                                       nature of the transaction. For example; it
                                                       is clear from the transaction structure that
                                                       giving an undertaking to the beneficiary
                                                       was not the purpose behind issuing the
                                                       documentary credit.
Illustration   Transaction structure appears unnecessarily complex:
               Party ‘A’ enters into the contract with party ‘B’ for import of goods through
               documentary credit. The underlying agreement is that Party ‘B’ (the
               beneficiary) will send some regulatory documents directly to the applicant.
               Documentary credit only requires that all regulatory documents like: fumigation
               certificate, phyto-sanitary certificate, quarantine certificate etc. be directly sent
               to the applicant by the beneficiary. The credit also requires being transferable.
               Bank ‘X’ opens a transferable LC with the above condition, which is
               subsequently transferred to 2nd beneficiary. The issuing bank has received
               presentation from the transferring bank which indicates that 2nd beneficiary


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                                                                      Appendix B



assigned its proceeds to the third parties and requests the issuing bank to pay
directly to the third party.
Considering the above case, there are few elements that may be considered as
alerts, i.e.
1. The beneficiary sends few regulatory documents directly to the applicant:
   By doing this, the beneficiary is able to keep the required regulatory
   documents outside the bank’s operational purview.
2. The LC is transferable: Under general circumstance, there is no harm in
   making the LC transferable. But the issuing bank should understand the
   reasonable ground for transfer. In some situations, the beneficiary
   sometimes insists on the condition to gain tax benefit and to create gateway
   to transfer fund from one country to another.
       Moreover, the issuing bank should have prior knowledge of the
       prospective 2nd beneficiaries and if possible restrict transfer within the
       beneficiaries. By doing this issuing bank has prior knowledge of those
       with whom they are dealing.
       Furthermore, the issuing bank should also understand whether it will
       restrict the transfer within the first beneficiary country or give authority
       to the transferring bank to make the transferred credit available in 2nd
       beneficiary’s country. The issuing bank should have prior knowledge
       about 2nd beneficiary’s country with whom the issuing bank intends to
       deal.
3. Assignment of proceeds: Even though it is not possible to have prior
   knowledge about request for assignment of proceeds until receipt of notice
   of assignment or indication in covering schedule, it is quite unusual to
   receive assignment of proceeds notice under transferable LC. Even in
   regular irrevocable LC, if the issuing banks receive assignment of proceeds
   notice, it indicates that the issuing bank is requested to deal with third
   parties other than the beneficiary.
       Assignment of proceeds under UCP 600 is always subject to applicable
       law and it will not be enforceable to the issuing bank until it
       acknowledges the assignment of proceeds. The issuing bank should
       conduct proper due diligence before crediting the documentary credit to
       third parties.
The above is only one example of how a documentary credit can become
unnecessarily complex. The Bank should consider every unusual request
beyond its regular standard practice under the purview of trade based money
laundering perspective. In fact opening Transferable LCs should be restricted to



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               2nd or 3rd.

Alert # 8      The customer engages in               Any trade transaction that deviates from
               transactions that are                 the customer’s existing line of business
               inconsistent with the customer’s      may have ill-motive to transact against
               business strategy or profile.         criminal proceeds or may simply move
                                                     money rather than goods through
               (Transaction is not in line with
                                                     accommodation of bill etc.
               the customer’s line of business
               or with his/her TTP)                  Hence, as part of trade specific due
                                                     diligence measures, banks should take
                                                     adequate measures to understand the
                                                     current trading profile of the customer
                                                     and its future plans on an ongoing basis.
                                                     Ensuring these, banks may identify which
                                                     trade products are suitable and which
                                                     trade products are vulnerable for a
                                                     particular trade customer at the outset of
                                                     a trade relationship. The measures will
                                                     also help them identify the extent of
                                                     deviation of a particular trade transaction
                                                     from the customer’s strategy and future
                                                     plans.
Illustration   Company ‘X’ imports garlic, cardamom etc. through Bank ‘A’ regularly.
               Suddenly he approaches bank to import 10,000 MT of rice, inconsistent with
               his regular import items. The underlying purpose may be to facilitate hiding the
               true beneficial owner of the transaction. This may also be applicable where the
               customer approaches bank to open LC for larger quantity than his regular
               import volume without having any reasonable ground or any business
               expansion.
               Company ‘Y’ generally imports metals but suddenly opened an LC to import
               some electronics which are unusual and prices are unknown to the market. In
               this way value can be transferred using such new items of goods. It may be that
               both the importer and the exporter are sister concern managed by the
               shareholders. As there may not be any physical movement of the goods, the
               respective transaction has no economic value other than transfer of money from
               the importer to exporter in the guise of trade.
Alert # 9      The Trade Finance transaction contains non-standard terminology and/or
               non-standard clauses.




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             Documentary credits often stipulate very standard clauses as documents
             requirement, which is by its nature very traditional. If a bank receives an export
             LC or the customer approaches bank to open an import LC with non-standard
             terminology or clauses, it may be an indication that the counterpart is trying to
             convince bank of the creditworthiness of the party and legitimacy of the
             underlying transaction.
             Examples:
             Non Standard Terminologies in documentary credit:
                  Assignable
                  Divisible
                  Unconditional
                  Unconditional revolving etc.
             Non Standard Clauses in documentary credit:
                  Ready, willing and able”
                  “Letter of interest”
                  “proof of product”
                  “The funds are “good, clean and cleared, of non- criminal origin”
                  “This is a bearer instrument letter of credit”
                  “to be advised between applicant and beneficiary”
                  “A prime bank guarantee issued by one of the top 50 or 100 world banks
                   or a cash wire transfer” etc.
             The above mentioned indications on a documentary credit are very unusual. In
             such cases banks should further scrutiny.
Alert # 10    Frequent amendment/extension         An LC that has been repeatedly amended
             /cancellation pattern.                should be treated carefully. After an
                                                   excessive number of amendments, the
                                                   parties should be required to have a new
                                                   LC issued. Correction of a slight
                                                   misspelling of a beneficiary name or of
                                                   the company designation (i.e. “LLP” vs.
                                                   “Corp.”), should be handled as a transfer
                                                   rather than as an amendment.
Alert # 11   The transaction appears to            Banks should look at the geographic
             involve the use of front or shell     location and addresses of the parties to a
             companies for the purpose of          transaction paying special attention to
             hiding the true parties involved.     those countries or areas where front or



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                                                                                Appendix B



                                                 shell companies are known to operate. If
                                                 a bank suspects that a party could be a
                                                 front or shell company, it should take
                                                 adequate steps to determine the identity
                                                 of the suspect entity and whether the
                                                 entity is designed to hide the true nature
                                                 of the participants to the transaction.
Alert # 12   Guarantee/Standby LC fails to      When a bank issues guarantee, or receives
             reference underlying project or    counter guarantee ultimately to issue
             contract.                          guarantee, it may fail to incorporate all the
                                                required information including reference
                                                of underlying projects.
                                                Hence, banks need to ensure the apparent
                                                authenticity of the underlying contract,
                                                bid etc. based on which the guarantee is
                                                being issued. If beneficiary of the
                                                guarantee is a government entity, then it
                                                could be easily verified via their website.
                                                In case of private beneficiary extra due
                                                diligence should be applied for the
                                                underlying contract. e.g copy of the
                                                contract, copy of paper announcement etc.

Alert # 13   Fake underlying transactions       Banks need to ensure the identity of the
             against a guarantee/SBLC/LC.       applicant, beneficiary and the underlying
                                                documents in order to avoid conflict of
                                                interest. Guarantee might be fake if both
                                                applicant and beneficiary are related
                                                entities and there is no such underlying
                                                transactions/performance. It can be
                                                executed through KYC for the parties in
                                                order to confirm that no same parties or
                                                related/common interest parties are
                                                involved in them.

                                      Value/Price
Alert # 14   The price is unusual, e.g. very   Buyer and seller negotiate price and the
             high or very low.                 pricing is based on quality and costs of the
                                               goods, packaging, freight, customs duties,
                                               documentation        preparation       fees,



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                                                    inspection fees, insurance and many other
                                                    factors. Therefore, it may not be easy for
                                                    banks to ascertain the market price for all
                                                    the components and circumstances that go
                                                    into the price of a product. Bank officials
                                                    should take adequate measures to try to
                                                    identify any blatant or obvious pricing
                                                    irregularities that may indicate the
                                                    inconsistencies of pricing of the goods
                                                    being shipped.
                                                    Also note para 20 of Chapter 7 of GFET,
                                                    2018.

Illustration   Typology: 1
               Company ‘X’ approaches Bank ‘B’ to open LC to import mobile phone or car.
               The price that as revealed in the proforma invoice is very low as compared to
               local market price. Moreover, the customs authority fixes certain amount or
               percentage of duty based on per piece etc. to prevent duty or tax evasion. The
               reason for quoting unit price very low may be for adjustment of debt which
               arises out of conducting transaction through informal or alternate remittance
               system.
               Typology: 2
               Company ‘X’ approaches Bank ‘C’ to open LC to import certain goods. Bank
               ‘B’ faces difficulties in knowing the exact unit price due to the nature of goods
               like capital machinery or chemical mixture etc. In some cases, local duty or tax
               is very nominal as the underlying goods have correlation with the economic
               development of the country.
               Typology: 3
               Company ‘X’ approaches Bank ‘D’ to open LC for import of rice or onion.
               The importer made certain percentage of advance payment through informal
               channel and opened LC up to the value where customs authority has reference
               value for custom valuation. But the actual price is higher than that of reference
               value. By doing so, the importer is able to avoid custom duty and taxes for the
               advance payment made. Similarly, excess amount of freight and other charges
               may also be taken into consideration.

Alert # 15     Under Invoicing (against             Invoicing goods at a price below the fair
               market price).                       market price, the exporter can transfer
                                                    value to the importer. Here the importer



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                                                 receives high value goods at a lower price.
                                                 After re-selling the goods importer
                                                 receives full value and thus additional
                                                 value is received by the importer from
                                                 exporter     through      under-invoicing.
                                                 Importer is also able to pay less customs
                                                 duty/tax by under-invoicing.
                                                 Trade processors should follow the
                                                 mechanism and guidelines to be
                                                 established by their own bank in
                                                 pursuance with these guidelines.
Alert # 16   Over Invoicing (against market      Invoicing goods at a price above the fair
             price).                             market price value can be transferred from
                                                 importer to exporter. Bank should frame
                                                 appropriate policy in this regard and trade
                                                 processors should follow the same.

Alert # 17   Invoice showing significant         Money can also be transferred from one
             amount of misc. charges e.g.        country/party to other country/party
             handling charges.                   showing significant amount of misc.
                                                 charges/handling charges/ unidentified
                                                 charges/in the invoices of goods/services
                                                 for laundering purpose.
                                                 Bank should know the justification
                                                 behind such unusual charges and act
                                                 accordingly to prevent TBML.

Alert # 18   There are indications of double     Double Invoicing: This is very much
             invoicing / Multiple Invoicing.     relevant for local trade transaction.
                                                 Double invoicing is where a subsidiary
                                                 purchases goods from a parent at too high
                                                 a price, or a parent purchases from a
                                                 subsidiary at too low a price.
                                                 Multiple Invoicing: This is also very
                                                 much relevant for local trade transaction.
                                                 More than one invoice for the same
                                                 international trade transaction, which
                                                 enables a money launderer or terrorist
                                                 financier to justify multiple payments for




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                                                 the same shipment.
                                                 Though with the establishment of FX
                                                 Dashboard, multiple invoicing is very
                                                 hard to do onshore, reasonable care should
                                                 be taken in case of off shore.

                                     Payment
Alert # 19     The payment terms appear      An importer or exporter may default
               inconsistent with the         willfully and launder money if payment
               transaction.                  terms of the financing is made without
                                             due consideration to the nature and/or
                                             conversion cycle of the underlying goods.
                                             For example, if an importer is financed
                                             for 365 days to import perishable goods
                                             like onin etc., when his business is to sell
                                             fish, he may abuse the facility and
                                             launder money through different ways
                                             (send money abroad through over
                                             invoicing with bank’s finance, or may go
                                             willful default and use the money to
                                             launder or finance terrorism etc.). Hence,
                                             taking into consideration the market
                                             practice and business of the buyer and
                                             seller banks should determine whether
                                             payment terms are consistent with the
                                             nature and asset conversion cycle of the
                                             goods being shipped and act accordingly.

Alert # 20     The transaction involves the      As third party payment arrangements can
               receipt of payments from third-   be used to disguise the identity of the true
               party entities that have no       payor and true source of funds, they may
               apparent connection with the      expose to the risk of money laundering
               transaction.                      and/or unwanted sanctions evasions.
                                                 Banks need to know and be satisfied with
                                                 the underlying arrangement with the 3rd
                                                 party who pay or receive the payments of
                                                 the trade transaction.

Illustration   Bank ‘I’ issues an LC for raw cotton from Uzbekistan and LC available with
               any bank in UAE with an advising bank in UAE. After making shipment,
               while the beneficiary is trying to make presentation, UAE bank refuses to



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             handle the transaction. Later on the beneficiary makes direct presentation to
             the issuing bank. Bank ‘I’ makes an attempt to make the payment through
             MT103, which its foreign correspondent bank refuses to process. Much later,
             the beneficiary makes the presentation through his bank in Latvia where the
             beneficiary maintains business account and Bank ‘I’ effects payment
             accordingly.

Alert # 21   Changing the place of payment       Banks should take into account that in
             i.e. payment is to be made to       some instances, beneficiary under an LC
             beneficiary’s account held in       directly sends documents to the issuing
             another country other than          bank within instruction to effect payment
             beneficiary’s stated location.      to a third country. This situation may
                                                 arise either the beneficiary is not able to
                                                 route trade document through banking
                                                 channel due to possible sanction hits or
                                                 trying to park the proceeds in relatively
                                                 lax jurisdiction.

Alert # 22   Payment instruction changes in      It should be borne in mind that last
             the last minute without any         minute changes to payment instructions,
             reason.                             inconsistent with the terms of the trade
                                                 instrument, or instructions to effect
                                                 payment to a third party or account
                                                 unrelated to the trade instrument could
                                                 indicate unusual activity.

Alert # 23   Applicant (customer) controls      The trade finance transaction includes a
             the payment.                       feature by which the buyer effectively
                                                controls the payment. This could indicate
                                                that the seller and buyer are colluding in a
                                                non-competitive manner and that they
                                                have an underlying relationship outside
                                                an expected trading relationship which is
                                                not known to the banks.

             Applicant (customer) controls the payment:
             Bank ‘X’ issues sight LC with a condition that payment will be effected upon
             receipt of applicant’s acceptance regarding receipt of goods in good order.
             This type of clause enables applicant to control payment. Providing such
             condition, the applicant can actually delay the payment though inconsistent
             with its nature of goods or local regulations. In other word, there might be
             collaboration between the buyer and seller beyond the knowledge of the bank.



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               Bank that issues LC with applicant control documents should be aware about
               requirement of applicant control and underlying transaction. Such as: import of
               capital machinery may be done with provision of split presentation as under:
                      - 15% advance payment
                      - 70% upon presentation and
                      - The rest 15% after proper installation of the capital machinery
                      supported by applicant certificate
               For import of capital machinery, the above split payment is customary. But
               split presentation or shifting payment obligation from beneficiary’s
               presentation to applicant control document for trading items or industrial raw
               materials import, may need further analysis.
Alert # 24     Claimed/lodged shortly while         Long tenor guarantee is normally issued
               guaranty validity is a long          against    a     long    term     contract/
               tenor.                               project/performance (i.e 24 months
                                                    period). The guarantee claim is supposed
                                                    to be placed after a reasonable long
                                                    period of time when applicant fails to
                                                    execute that long term project/contract. If
                                                    situation arises that a claim is lodged
                                                    within a short time after the guarantee is
                                                    issued, e.g. one month, the guarantee
                                                    issuing bank should take it as an alert and
                                                    should perform proper due diligence by
                                                    confirming the genuineness of the claim
                                                    from the beneficiary office.

Alert # 25     Issuance of fraudulent Letter of     Bank should have independent policy in
               Undertaking (LoU).                   place to operate SWIFT system which
                                                    includes checker and maker system and
                                                    periodic auditing, both by internal and
                                                    external auditors.
                                                    In addition, SWIFT system should be
                                                    integrated with their core banking system
                                                    (CBS).

Illustration   Two employees of ‘XYZ Bank’ send unauthorized Letters of Undertakings
               (LoUs), essentially bank guarantees, to foreign banks, on behalf of their
               customer M/s. ‘ABC Gems Ltd’. owned by “Mr. X”. The LoUs were
               undertaken to make payment in favor of foreign beneficiary for imports if on




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             maturity, importer fails to pay, ‘XYZ Bank’ would make the payment.
             On receipt of guarantee foreign bank provides loan to the importer. The tenure
             of this loan varies from ninety days up to even five years for capital goods.
             The money gets used to settle the payment for imports.
             The money raised through this guarantees is not used to make payments for
             imports rather used to settle loans taken earlier. In fact, every time a firm
             related to Mr. ‘X’ asks for a bank guarantee, it is to settle an older loan taken
             through a previous bank guarantee. Thus, the amounts go up to around BDT
             11,4000 million.
             LOUs were issued without any collateral or any usual process of the bank
             through colluding two bank officials of ‘XYZ Bank’ and the ‘XYZ Bank
             employee sends these guarantees in the absence of credit limits and collateral
             security. Secondly, he does not make an entry in the bank’s Core Banking
             Software (CBS). In some cases, a corresponding entry is made in the core
             banking system, but for lower amounts. Even regular audits may not find it.
             Bank’s reconciliation department also could not find out the mismatch.
             It is revealed that in the said Bank, there is no SWIFT operating procedure in
             place, SWIFT is not integrated with the Bank’s CBS and the SWIFT operation
             of that is not centralized and absence of proper auditing system i.e. IT audits
             did not take place.
             On this pretext, the ill motive customer was able to complete the evil scheme
             with the support of colluding employees of the Bank. Using such valid tools,
             dishonest officials of the bank in collusion can launder money.

                          The goods and size of shipment
Alert # 26   There are no goods (Phantom      Banks should be aware that under these
             Shipment)                        circumstances      the    beneficiary    or
                                              applicant refuses to provide documents to
                                              prove shipment of goods (possible
                                              phantom shipping or multiple invoicing).
                                              For Example: LC or bank guarantee
                                              purportedly covers the movement of
                                              goods but fails to call for presentation of
                                              transport documents. LC covers steel
                                              shipment but allows a forwarders cargo
                                              receipt (FCR).
Alert # 27   No goods description mentioned        Not having goods’ description is itself an
             in documents/                         alert. Bank should know the goods or



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              Descriptions of the                  services of underlying transaction from
              goods/services are not clear or      the related trade documents, such as LC,
              are coded or disguised.              BL, invoice etc.

Illustration As we know from documentary credit operation that Banks deal with
for Alerts documents not with underlying goods, service or performance, issuance of LC
26 & 27      without asking for transport document or allowing copy of transport document
             to be presented may facilitate phantom shipment. In addition to that
             documentary credit containing a condition “document acceptable as presented”
             or “all discrepancy accepted except value and quantity” may also have similar
             implication.
              Client may approach for issuance of local LC with above clause or without
              mentioning description of the goods. The inherent agenda in such cases may
              be to avail loan from the bank under the banner of trade finance.

Alert # 28     The customer deviates               Banks need to understand the customer’s
               significantly from its historical   traditional business patterns as part of the
               pattern of trade activity (in       trade specific customer due diligence
               terms of markets, monetary          process that reviews and examines the
               value, frequency of                 customer’s business activity, such as the
               transactions, volume, or            frequency of shipments, the value,
               merchandise).                       volume, types of products and/or services
                                                   in which the customer typically deals.
                                                   Banks should have processes that will
                                                   identify significant variations in these
                                                   trading patterns.

Alert # 29     Transaction involves obvious        Dual use items are goods, software,
               dual use goods.                     technology, documents and diagrams,
                                                   which may have both civil and military
                                                   applications. Identification of dual use
                                                   goods is difficult given their possible
                                                   complex and technical nature. While
                                                   banks may be in a position to identify
                                                   obvious dual use of goods, corporate
                                                   clients should be best suited for making
                                                   this determination. Each bank should
                                                   refer to its own policies and procedures
                                                   on how to appropriately identify and
                                                   address the identification and handling of
                                                   such goods.



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Appendix B: TBML Alerts — Slide 15 PDF page 69

                                                                                    Appendix B



Illustration   Though most of the banks are aware of obvious sanctioned country under
               UNSCR lists and generally do not open LCs where shipment is made from
               sanctioned port, company ‘X’ opened LC for import of bitumen from UAE
               mentioning any port of UAE and the respective transport document i.e. Bill of
               lading also mentions shipment from Jebel Ali, a UAE port inconsistent with
               the LC terms. But later on upon analysis of shipment routing, it is revealed that
               the ship indeed started its journey from the Jebel Ali but instead of moving
               toward Chittagong, it went to Bandar Abbas (an Iranian port) then came back
               to Jebel Ali and then started journey towards Chittagong.
               Moreover, Bank should also be careful in importing goods from certain
               country where underlying goods is not within the exportable basket of the
               exporting country.

Alert # 30     Different HS Code is used.           In trade documents (i.e. LC, Invoice, EXP
                                                    etc.) different HS code may be used to
                                                    avoid high rate of customs duty. Bank
                                                    should identify the goods description with
                                                    appropriate HS Code as per Customs First
                                                    Schedule of Bangladesh.

Alert # 31     Quantity of goods exceeds the        Under shipment, over shipment, no
               known capacity of the shipping       shipment might occur when quantity of
               containers or tanker capacity or     mentioned goods exceeds the capacity of
               abnormal weights for goods are       the shipping containers/ tanker. Bank
               suspected.                           should try to know apparent capacity of
                                                    the container, tanker etc.

Alert # 32     High risk goods/services are Goods/Services are assigned as high risk
               involved.                    when those particular items           of
                                            goods/services are used for illicit
                                            purposes.
                                                    Bank management should make relevant
                                                    officials aware of the high risk goods and
                                                    services from time to time.

                                            Transport
Alert# 33      Transportation route/              Commercial banks should take into
               information is inconsistent with   consideration whether the transport
               underlying transaction.            route appearing in documents is unusual
                                                  or inconsistent. It may be that the
                                                  transport route does not make sense for
                                                  the purpose of the customer/goods


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Appendix B: TBML Alerts — Slide 16 PDF page 70

                                                                                 Appendix B



                                                  shipped. It may also be that the actual
                                                  transport route is inconsistent with the
                                                  expected and documented transport
                                                  route.

Alert# 34    Transshipment through a              Nature of goods, applicant & beneficiary
             country for no apparent reason.      country distance/location does not
                                                  justify transshipment or transshipment
                                                  from a country which is geographically
                                                  absurd.
                                                  For example: Shipment of raw cotton
                                                  from Singapore, which is unusual.

Alert # 35   The mode or method of               If the mode of shipment and shipping
             shipping is unclear or the          route is not clear or kept hidden, there
             shipping route is unclear.          might be involvement of some sanctioned
                                                 /embargoed country/port/location/entities
                                                 Banks should perform due diligence to
                                                 identify the mode and route of the
                                                 shipment.

Alert # 36   Goods to be shipped from one        Bank should check the valid reason for
             country/place but supplier/         the shipment from a third country where
             beneficiary is located in another   beneficiary is not located. There might be
             country/place.                      underlying illicit arrangement between
                                                 the beneficiary and the party in third
                                                 country from where shipment is made.

Alert # 37   Vessel/Container number             Container number consists of an
             cannot be tracked through web       internationally      standard        format.
             search.                             The number includes four letters and
                                                 seven digits, with the last digit referred to
                                                 as the check digit. (i.e. XXXU1234567).
                                                 It is used for documentation purposes,
                                                 including invoice, consular statement, bill
                                                 of lading and others. Vessels can also be
                                                 tracked through web link. Banks should
                                                 check the vessel tracking /container
                                                 tracking through web link to ensure that
                                                 the vessel/ container number appearing in
                                                 the documents is valid.




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Appendix B: TBML Alerts — Slide 17 PDF page 71

                                                                                Appendix B



Alert # 38    The bill of lading describes       If bill of lading/shipping document does
              containerized cargo but            not contain the container number while
              without container numbers or       the goods are shipped through
              with sequential container          containerized cargo, banks need to
              numbers.                           further scrutinize and ensure that the
                                                 shipments appearing in the document is
                                                 valid.
                     Country/Jurisdiction/Geographical Location/Sanction
Alert # 39   Customer shipping items to,       Banks should understand where the
             through, or from higher money     customer undertakes business and on
             laundering risk jurisdictions     what basis as part of trade specific
             including countries identified by customer due diligence activities. As
             FATF as stated in FATF Public     some countries, entities and individuals
             document.                         present heightened risk for financial
                                               crimes, care should be exercised to
                                               understand the rationale for the customer
                                               conducting business in higher risk
                                               jurisdictions. To the extent possible,
                                               banks should determine if there is a valid
Alert# 40    Transaction involves high risk
                                               reason, and if the business is within their
             jurisdiction/country.
                                               risk parameters.
                                                 Banks should maintain a list of
Alert# 41    Transaction involves sanctioned     jurisdictions identified by relevant bodies
             entities /countries /individuals.   (e.g. FATF) that present high risk in
                                                 terms of money laundering, terrorist
                                                 financing or other financial crimes.
                                                 Transaction     with     UN      sanctioned
                                                 countries, individuals and entities should
                                                 be avoided. Transaction or relationship
                                                 with local sanctioned individuals and
                                                 entities should also be avoided. All the
                                                 lists should be made available to the trade
                                                 operations area and updated as necessary.

                                    Discrepancies
Alert # 42   Goods’ description in the         Examples:
             documentary credit.                  There are significant discrepancies
                                                  between the description of the goods
                                                  on the bill of lading (or invoice) and



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Appendix B: TBML Alerts — Slide 18 PDF page 72

                                                                                 Appendix B



                                                       the documentary credit, i.e. it is
                                                       apparent that they are not the same
                                                       type of goods.

Alert# 43      Clauses in the documentary          If clauses in the documentary credit are
               credit.                             not examined and addressed carefully by
                                                   the bank, colluding parties may abuse
                                                   trade and perpetrate TBML.

Illustration   Clauses in the documentary credit:
               Bank ‘I’ issued LC for or on behalf of the customer ‘X’ in favour of the
               beneficiary ‘Y’ for import of raisin. After issuance of LC, the customer
               remitted 15% of actual goods value through informal channel. As soon as the
               beneficiary ‘Y’ received fund, the beneficiary ‘Y’ demanded an amendment
               for addition of clause “document acceptable as presented” or “all discrepancy
               acceptable except value and quantity”. Bank ‘I’ issued the amendment
               reluctantly. Later on, the beneficiary made presentation except pre-shipment
               inspection certificate and phytosanitary certificate. Upon analysis, it was
               revealed that quality of the shipped goods was inferior and not fit for human
               consumption but the fact is that the presentation was complying due to the
               amendment.

Alert # 44     Essential documents presented       Essential documents such as invoices or
               in copy form or not presented.      transport documents are missing or
                                                   presented in copy form.

Alert # 45     Waivers: Amount significantly       The documentary credit / guarantee is
               overdrawn, Advance waivers          significantly overdrawn; i.e. the drawing
               provided etc.                       under the documentary credit/ guarantee
                                                   is significantly above the outstanding
                                                   amount of the documentary credit /
                                                   guarantee.

Illustration   Essential documents presented in copy form or not presented:
44 & 45        Waivers: Amount significantly overdrawn, Advance waivers provided etc:
               Bank ‘I’ issued LC favoring the beneficiary ‘Y’ for its new customer ‘X’
               under 50% margin. The beneficiary made presentation of copy of bill of lading
               instead of original. The customer approached banks to waive the discrepancies,
               which later on agreed after depositing 100% margin. Bank ‘I’ effected
               payment accordingly.
               After a few days, the bank received another presentation under documentary
               collection with payment instruction to deliver documents against payment for


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Appendix B: TBML Alerts — Slide 19 PDF page 73

                                                                                 Appendix B



             different customer of the Bank ‘I’. After checking documents, it was found
             that the original bill of lading of the earlier LC related documents had been
             presented. Moreover, the beneficiary was also different from the LC. In the
             meantime, the new customer also disappeared. Bank should take into
             consideration the type of discrepancy they are given waiver and should have
             an understanding of its after effect.
             Sometimes, it is also seen in local documentary credit practice that bankers
             generally allow 10% excess payment on the plea of 10% tolerance level with
             or without LC conditions. While affecting such type of payment, bank should
             take due care of nature of goods, applicability of tolerance and change in unit
             price etc.
Alert # 46   The customer is overly keen to       Banks need to understand the motive
             waive discrepancies.                 behind the customer’s keenness to accept
                                                  the discrepancies and the gravity of the
                                                  discrepancies. Although this is not related
                                                  to trade rules, additional responsibility in
                                                  respect of KYC (Know Your Customer),
                                                  DD (Due Diligence) and EDD (Enhanced
                                                  Due Diligence) have been vested on the
                                                  bankers. When acceptance is provided by
                                                  the importer to the discrepant documents,
                                                  the banker should verify the kind of
                                                  discrepancy accepted and whether this
                                                  may pose money laundering risk.

                                    Unusual Documentation
Alert # 47   Documents required or              Banks should be cautious if documents
             presented is unusual to related    appear to have been altered, fraudulent,
             trade transaction.                 are inconsistent or illogical, or when
                                                documentary presentations do not include
                                                required transport documents, as this
Alert# 48    There are indications that         could be an indication of unusual
             documents have been reused.        activity.
                                                  Although the failure of documents to
                                                  appear on their face to comply with the
                                                  terms and conditions of an LC may be
                                                  routine discrepancies, certain unusual
                                                  discrepancies may require additional due
                                                  diligence.



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Appendix B: TBML Alerts — Slide 20 PDF page 74

                                  Appendix B



     Examples include the presentation of
     documents showing a place of origin,
     loading, transshipment or destination
     entirely inconsistent with what is
     expected, the presentation of documents
     showing goods description entirely
     inconsistent with the expected goods, and
     the presentation of documents showing
     much higher or lower values or costs than
     expected.




66

Appendix C: Product-wise TBML alerts, relevant lists and examples

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Appendix C: Product-wise TBML alerts, relevant lists and examples — Slide 1 PDF page 75

Appendix C: Product wise TBML Alerts, Some Relevant Lists and
                          Examples

Some of the important Products specific TBML alerts are given below. They do not
eliminate the alerts mentioned in Appendix B.
TBML Alerts common to almost all the products below and therefore should be guarded
against are:
    i. Under Invoicing(against market price)
   ii. Over Invoicing (against market price)
  iii. Underlying goods is not in line with the customer’s line of business.
   iv. Descriptions of the goods are not clear or are coded or disguised.
   v. The method of payment appears inconsistent with the risk characteristics of the
      transaction.
   vi. The transaction involves sanctioned entities.


Issuance of LC/LCAF
Price, Quantity and descriptions of Goods:
a. High risk goods or high risk jurisdiction/country is involved.
b. Transaction involves restricted or banned items of goods.
c. Different HS Code is used

Mode and Location of Shipment:
 Goods to be shipped from one country/place but supplier/beneficiary are located in
  another country/place and payment to be made to a different 3rd country/place.
 The mode or method of shipping is unclear or the shipping route is unclear.

Payment Method:
a. Changing the LC beneficiary or collection payee name and address just before payment is
   to be made. Including requests for assignment of proceeds or transfer at the time
   documents are presented.
b. LC transfer or assignment of proceeds request names a transferee or assignee in an
   offshore financial haven. Request for transfer, assignment or other financing under an LC
   which has expired or not in effect.
c. The customer offers to pay unusually high fees to the Bank.




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Appendix C: Product-wise TBML alerts, relevant lists and examples — Slide 2 PDF page 76

Applicant, Beneficiary and Other Parties/Entities Involved:
a. Supplier’s credit report is not available.
b. Supplier’s line of business is not in congruence with the goods imported.
c. Transaction is not in line with the customer’s TTP (Trade Transaction Profile) or when an
   exporter steps outside normal business activities.
d. Any of LC parties are known to be owned or controlled by senior public
   figure.Transaction involves an unusual intermediary (e.g. middleman is travel agency
   handling shipment of machine parts) or too many intermediaries making transaction
   overly complex.

LC Clauses and Required Documents:
    i. Unusual/non-standard clause is inserted in the LC.
   ii. LC without regulatory required documents.
   iii. Significantly amended letters of credit without reasonable justification or changes to
        the beneficiary or location of payment.


Import Bill (Scrutiny/Acceptance/Payment/Financing) & Export Bill (Scrutiny/
Financing/ Payment)
Price, Quantity and Descriptions of Goods:
 Under Shipment (in terms of quantity)
 Over shipment (in terms of quantity)
 Discrepancies in Goods description, quantity and shipment locations.
 Where the quantity of goods exceeds the known capacity of the shipping containers or
  tanker capacity. Or where abnormal weights for goods are suspected.

Invoice:
 There are indications of double invoicing.
 Invoice showing significant amount of misc. charges e.g. handling charges.
 The documentation appears illogical, fraudulent and/or improperly modified from its
  original content, or certain documentation is absent that would be expected given the
  nature of the transaction.

Transport & other Documents:
    i. The bill of lading describes containerized cargo but without container numbers or
       with sequential container numbers.
   ii. Phantom shipment - where no goods are shipped at all and the documentation is
       completely falsified
   iii. The mode or method of shipment is unclear or the shipping route is unclear.


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Appendix C: Product-wise TBML alerts, relevant lists and examples — Slide 3 PDF page 77

    iv. Vessel / Container number cannot be tracked through web search.
    v. There are indications that documents have been re-used.
    vi. There are dubious unauthorized alterations or amendments to the documents.

Payment Methods:
a) Payment is to be made to beneficiary’s account held in another country other than the
   Beneficiary’s stated location.
b) Payment is to be made to personal A/C of beneficiary instead of company A/C.

Others:
   The customer is overly keen to waive discrepancies.
   Transaction involves an unusual intermediary (e.g. middleman is travel agency handling
    shipment of machine parts) or too many intermediaries making transaction overly
    complex.


Export LC Advising
High risk goods or high risk jurisdiction/country is involved as per Appendix B.
   Transaction involves restricted or banned items of goods.

Export LC/Contract Lien and Pre-shipment financing (B2B facility/Packing
Credit/Working Capital Loan):
Price, Quantity and descriptions of Goods:
   High risk goods or high risk jurisdiction/country is involved.
   Transaction involves restricted or banned items of goods.

Mode and Location of Shipment:
   Goods to be shipped from one country/place but supplier/beneficiary are located in
    another country/place and payment to be made to a different 3rd country/place.
   The mode or method of shipment is unclear or the shipping route is unclear.

Payment Method:
Applicant, Beneficiary and Other Parties/Entities Involved:
   Bonafides of buyer is not known.
   Buyer’s line of business is not in congruence with the underlying goods.
   Transaction is not in line with the customer’s TTP (Trade Transaction Profile) or when an
    exporter steps outside normal business activities.
   Any of LC parties are known to be owned or controlled by senior public figure.



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Appendix C: Product-wise TBML alerts, relevant lists and examples — Slide 4 PDF page 78

   Transaction involves an unusual intermediary (e.g. middleman is travel agency handling
    shipment of machine parts) or too many intermediaries making transaction overly
    complex.

LC Clauses and Required Documents:
   Unusual/non-standard clause is inserted in the LC.
   LC without regulatory required documents.
   Significantly amended letters of credit without reasonable justification or changes to the
    beneficiary or location of payment

Shipping Guarantee
IDO/Shipping Guarantee is just copy document endorsement by bank and in addition bank
issues a shipping guarantee favouring shipping company. While issuing IDO/Shipping
Guarantee, TBML alerts relevant to IDO/Shipping guarantee mentioned below should be
taken into consideration:

Price, Quantity and Descriptions of Goods:
     i. Under Shipment (in terms of quantity)
    ii. Over shipment (in terms of quantity)
    iii. Discrepancies in Goods’ description, quantity and shipment locations.
    iv. where the quantity of goods exceeds the known capacity of the shipping containers or
        tanker capacity. Or where abnormal weights for goods are suspected.

Invoice:
     i. There are indications of double invoicing.
    ii. Invoice showing significant amount of misc. charges e.g. handling charges.
    iii. The documentation appears illogical, fraudulent and/or improperly modified from its
         original content, or certain documentation is absent that would be expected given the
         nature of the transaction.

Transport & other Documents:
     i. Original import documents against the LC are already in the bank.
    ii. There are indications that documents have been re-used.
    iii. Transport document is not endorsed to the order of the bank as per LC terms.




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Appendix C: Product-wise TBML alerts, relevant lists and examples — Slide 5 PDF page 79

Guarantee/Standby Letter of Credit (SBLC)
   i. Guarantee/ Standby LC fails to reference underlying project or contract (except for
      insurance related LCs, where the LC calls for a draft only. This is an acceptable
      practice).
   ii. Applicant and beneficiary are related party and there is common interest.
  iii. Claimed/lodged shortly whilst guaranty validity is a long tenor.
  iv. Fake underlying transactions.
   v. In case of transfer, there is a possibility to effect payment to a sanctioned or AML
      related party.

Service Export
   a) Swift message does not mention any purpose of the transaction.
   b) The reference number of underlying service contract/LC/Invoice is not mentioned in
      the Swift payment message.
   c) Importer and exporter are related parties.
   d) Description of service is not clear.
   e) Exporter and importer line of business do not support the services.
   f) Exporter is not capable of providing those underlying services.
   g) Payment received from a third party not mentioned in underlying contract.
   h) Price of service unusually high or low.


NOTE: All the TBML alerts stated above are subject to change based on change in the
nature and magnitude of trade based ML/TF.




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Appendix C: Product-wise TBML alerts, relevant lists and examples — Slide 6 PDF page 80

                          1. Sample Trade Transaction Profile (TTP)

General Information:
Customer Name & Address:
IRC number:
ERC number:
BEPZA/EZ permission no:
BIN No.:
Vat reg. No.:
TIN No.:
Particulars of Business                             Details
Type of Business (Commercial/Industrial/Others)
Nature of Business (RMG/Textile/
Pharmaceuticals/Trading/Agro etc.)
Import items [including service/performance]
Export items [including service/performance]
Types of Trade Loan from bank and other FIs
Types of Guarantee/Standby LC
Importing Countries
Exporting Countries


Transaction Information:
Details of Transactions                 Monthly Average        Monthly Average Value of
                                     Volume of Transactions   transactions in Million USD
Details                               Minimum     Maximum       Minimum        Maximum
Import LC Issuance
Import through Collection/Contract
Import payments
Export LC/Contract
Export Proceeds realization
Other invisible receipt ( inward
remittances)
Other invisible payment ( outward
remittance)
Guarantee/Standby LC
Import Loan (EDF/UPAS/LATR
/MPI/MIB/Bai Muazzal/ etc)



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Appendix C: Product-wise TBML alerts, relevant lists and examples — Slide 7 PDF page 81

Details of Transactions                   Monthly Average          Monthly Average Value of
                                       Volume of Transactions     transactions in Million USD
Details                                 Minimum     Maximum         Minimum        Maximum
Import Under Aid/Barter/or any
other special arrangements
Import payment through FC
account
Term Loan for Machinery Import
Export Loan foreign (Discounting/
Purchase/Bai As sarf/)
Local Export Loan (Discounting/
Purchase/Musharaka Documentary
Bills etc.)
Others



I/We the undersigned hereby confirm that the anticipated transaction amount and frequency
are my/company’s normal transactions. I/We further confirm that if necessary, I/we will
revise our transaction profile from time to time.

 Signature: ………………………………                          Signature: ………………………………
 Name: ……………………………………                             Name: ……………………………………
 Designation: ……………………………                         Designation: ……………………………
 Date: …………………………………….                            Date: …………………………………….



                                     For Bank’s Use Only

The Trade Transaction Profile (TTP) of the client has been reviewed in accordance with the
instructions of Bangladesh Financial Intelligence Unit (BFIU).



____________________________________________________
Designated bank official’s name (with seal), signature and date




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Appendix C: Product-wise TBML alerts, relevant lists and examples — Slide 8 PDF page 82

         2. Some Examples of Detection Scenarios based on TBML Alerts

         Detection Scenarios                                 Probable Rules
 Transactions through Land lock               Should be a Pre-transaction & Automated
  countries                                     detection; otherwise relevant officials should
                                                check against list of land lock countries.
 Unauthenticated Letter of Credits            Should be a Pre-transaction & Partly
  (LCs)/ Fake LCs                               Automated detection; Rest of physical
                                                inconsistencies should be checked against a
                                                trade-check-list by knowledgeable officials.
 Round figure relatively big-bill-            Should be a Post-transaction & Automated
  amounts submission/ payment                   detection alert/ report.
 Parties in Sanctions List/ High Risk         Should be a Pre-transaction & Automated
  Jurisdiction list                             detection; otherwise officials should check
                                                manually at-least against the key list of
                                                comprehensive –Sanctioned-country list (UN,
                                                OFAC, EU, HMT(BoE)
 Letter of Credit (LC) Overdrawn by           Should be a Pre-transaction & Automated
  large value                                   detection; otherwise offcials to check
                                                manually.
 Future dated bill of lading/ Pre dated       Should be a Pre-transaction & Automated
  bill of lading                                detection; otherwise officials to check
                                                manually.
 Trend to high risk countries                 Should be a Post-transaction & Automated
                                                detection alert/ report.
 Inconsistency with customer business         Should be a Post-transaction & Automated
  i.e. not in line with customer’s regular      detection alert/ report, however pre-checking
  activities                                    by knowledgeable officials is also highly
                                                recommended.
 Fraudulent documents/ Tampered               Should be a Post-transaction & Automated
  documents/ Phantom shipping                   detection alert/ report, however pre-checking
                                                by knowledgeable officials is also highly
                                                recommended.
 Payment to a third party or to unrelated     Should be a Post-transaction & Automated
  party                                         detection alert/ report, however pre-checking
                                                by knowledgeable officials is recommended.
 Same address of Beneficiary/                 Should be a Post-transaction & Automated
  Applicant, Drawer/ Drawee, Related            detection alert/ report, however pre-checking
  parties /other address inconsistencies        by knowledgeable officials is recommended.
 Discrepancies-that are Material in trade     Should be a Pre-transaction & Partial
  documents                                     Automated detection alert/ report, however



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Appendix C: Product-wise TBML alerts, relevant lists and examples — Slide 9 PDF page 83

             Detection Scenarios                                  Probable Rules
                                                     pre-checking by knowledgeable officials is
                                                     highly recommended.
   Trade Transaction related or involving          Should be a Post-transaction & Automated
    parties in tax havens e.g. Bermuda,              detection alert/ report, however pre-checking
    Bahams, Monaco, Jersey, Isle of Man,             by knowledgeable officials is recommended.
    Luxembourg, Ireland, Mauritius,
    Panama British Virgin Islands,
    Cayman Island etc.

Note: The Frequency of Report (Real-time/Daily/ Monthly) and the risk priority (High/ Medium/
Low) of the Alert can be assigned by respective Bank based on their Risk-Appetite, system &
resource capacity. However, no need to mention that, High risk alerts like Sanction-violation – should
be detected & worked upon preferably on real-time basis or at-least on daily basis with top priority.




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Appendix C: Product-wise TBML alerts, relevant lists and examples — Slide 10 PDF page 84

                     3. List of Landlocked Countries:

•   Afghanistan                     •   Mali
•   Angora                          •   Moldova
•   Armenia                         •   Mongolia Artsakh
•   Austria                         •   Nepal
•   Azerbaijan                      •   Niger
•   Belarus                         •   Paraguay
•   Bhutan                          •   Rwanda
•   Bolivia                         •   San Marino
•   Botswana                        •   Serbia
•   Burkina Faso                    •   Slovakia
•   Burundi                         •   South Ossetia
•   Central African Republic        •   South Sudan
•   Chad                            •   Swaziland
•   Czech Republic                  •   Switzerland
•   Ethiopia                        •   Tajikistan
•   Hungary
                                    •   Turkmenistan
•   Kazakhstan
                                    •   Uganda
•   Kosovo
                                    •   Uzbekistan
•   Kyrgyzstan
                                    •   Vatican City
•   Laos
                                    •   West Bank
•   Liechtenstein
                                    •   Zambia
•   Luxemburg
                                    •   Zimbabwe
•   Macedonia
•   Malawi




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Appendix C: Product-wise TBML alerts, relevant lists and examples — Slide 11 PDF page 85

                 4. Example of Few Sanctioned Vessels/Shipping Lines that
                                                changed names
Vessels:
  Abila - IMO 9213399          * Alvan - IMO 9165798           *Amina - IMO 9305192
    Arezoo - IMO 9165786 * Artin - IMO 9305221                 * Aysan - IMO 9165803
    Baseej-1 - IMO 8746301             * Basht - IMO 9346536           * Behnavaz - IMO
     9346548
    Behta - IMO 9349590 * Dadgar - IMO 9357729                 * Deniz - IMO 9569700
    Dew Drop - IMO 9569695             * Dusk - IMO 9569712            * Genco - IMO 9387798
    Golsan - IMO 9165815 * Iran Noor - IMO 9079066 * Klos C - IMO 8918710
    Lotus - IMO 9165827 * Manlai - IMO 9465851                 * Orang - IMO 9051650
    Oura - IMO 9387815         * Pendar - IMO 9209324          * Perarin - IMO 9209350
    Rosemary - IMO 9209336             * Sana - IMO 9209336            * Sarvin - IMO 9209348
    Shabdis - IMO 9349588 * Shahraz - IMO 9349576              * Touska - IMO 9328900
    Zardis - IMO 9349679 * Ka Rim Chon - IMO 8314811                                      *
     Sadaf Poshtiban - IMO 8422084


Shipping Lines:
    Aran Asman                         * Arash Mehr International Transport Co
        Caribbean Navigation Company           * Hafez Darya Arya Shipping Line
        IRISL                          * Payam Marand Tarabar
        RAHVAND                        * SOUTH SHIPPING LINE IRAN
        SEIBOW LOGISTICS LIMITED                       * NITC


The lists and examples mentioned above are not exhaustive. These are indicatives only.




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Annexure: Trade data and brief analysis

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Annexure: Trade data and brief analysis — Slide 1 PDF page 86

                      Annexure: Trade data and brief analysis
     Top 100 items Import LC/Contract opened during 2013-2017 in Bangladesh has been given
     below for Guidance only. How tax structure impacted import into Bangladesh can be inferred
     from the table.

SL                                                                   LC Value
         HS CODE                  Commodity Name                                            TTI
No.                                                               (USD in Millions)
 1        52010000    Cotton, not carded or combed                   12,250.44              0%

 2        99000000    Services                                       12,134.40
 3        10011990    Wheat and Meslin-> Other                        4,655.32              0%
                      Palm        Oil      (Excl.     Cude)&Its
 4        15119090                                                    4,581.69            20.07%
                      Fractns....Nes.Incld.Refiend Palm Oil
                      Vessels and other floating structures for                       1,500 BDT/MT +
 5        89080000                                                    4,258.56
                      breaking                                                        800 BDT/MT 4%
                                                                                      Specific Customs
 6        17011400    Other cane sugar                                4,010.88         taxes and duties
                                                                                        based on SRO
 7        27101262    High speed diesel oils,                         3,651.20            34.07%

 8        52094200    Denim, With >=85% Cotton, >=200g/M2             3,458.05            89.42%

                      Cement Clinkers, Imported by          Vat
 9        25231020                                                    3,055.80            625.40%
                      Registered Manufacturers of cement

10        27101911    Other Fuel Oils, Furnace Oils, TV               2,982.42            34.07%

                      Cellular (Mobile/fixed wireless) te
11        85171210                                                    2,814.81            28.50%
                      lephone set
                      Petroleum Oils And Oils Obtained From
                      Bituminous Minerals,Other Than Crude;
                      Preparations Not Elsewhere Specified Or
                      Included,Containing By Weight 70% Or
                      More Of Petroleum Oils Or Of Oils
12        27101150                                                    2,793.63            34.07%
                      Obtained         From       Bituminous
                      Minerals,These Oils Being The Basic
                      Constituents Of The Preparation;Waste
                      Oils --> Other Medium Oils And
                      Preparations

13        15071000    Crude Oil, whether or not degummed              2,670.27            20.07%




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Annexure: Trade data and brief analysis — Slide 2 PDF page 87

SL                                                                  LC Value
      HS CODE               Commodity Name                                                TTI
No.                                                              (USD in Millions)

14    62171000   Clothing Accessories, Nes                           2,305.62           127.84%

                 F./hot-rolled  ....Imp.      by    VAT
15    72083920   regdT.Former&       pre-fab.    building            2,077.77           37.07%
                 manufacind.
                 Soya beans, whether or not broken other
16    12019090   than Seed, EXCL. Wrapped/canned upto                1,844.28             0%
                 2.5 Kg
                 Petroleum Oils And Oils Obtained From
17    27090000                                                       1,755.46           31.07%
                 Bituminous Minerals, Crude TV

                                                                                     1,500 BDT/MT +
18    72044900   Ferrous waste and scrap, nes                        1,647.71
                                                                                     800 BDT/MT 4%

19    39021000   Polypropylene, In Primary Forms                     1,597.70           31.07%

                 Semi-Products Of Iron/Steel,         <0.25%
20    72071100                                                       1,597.01           844.08%
                 Carbon, Of Squarish Section

                 Urea, Whether Or Not In Aqueous
21    31021000                                                       1,524.80             0%
                 Solution

                 DiammoniumHydrogenorthophosphate
22    31053000                                                       1,471.73             0%
                 (Diammonium Phosphate)

                 Rice --> Semimilled Or Whollymilled                                 Variable (10%-
23    10063000                                                       1,468.61
                 Rice,Whether Or Not Polished Or Glazed                                   28%)

                 Oil-Cake And Other Solid Residues, Of
24    23040000                                                       1,265.00           15.57%
                 Soya-Bean Oil

25    27011900   Other Coal, Not Agglomerated, Nes                   1,184.27           25.07%

                 Mineral             Or              Chemical
26    31031020   Fertilisers,Phosphatic      -->        Triple       1,177.73             0%
                 Superphosphates
                 Other gas oils (EXCL. Lithg diesel oil
27    27101269                                                       1,166.35           86.42%
                 &high speed disel oils)

                 Wheat And Meslin --> Wheat/Mealing
28    10011090                                                       1,163.21             0%
                 Wheat




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Annexure: Trade data and brief analysis — Slide 3 PDF page 88

SL                                                               LC Value
      HS CODE               Commodity Name                                         TTI
No.                                                           (USD in Millions)

29    10063090   Semi-Milled Or Wholly Milled Rice                1,117.10         10%

                 Preparations Of A Kind Used In Animal
30    23099010                                                    1,115.87        10.32%
                 Feeding --> Poultry/Dairy/fish feed
                 Petroleum oils and oils obtained from
                 bituminous minerals,other than crude;
                 preparations not elsewhere specified or
                 included,containing by weight 70% or
31    27101169                                                    1,084.21        86.42%
                 more of petroleum oils or of oils obtained
                 from bituminous minerals,these oils being
                 the    basic     constituents    of    the
                 preparation;waste oils --> other
                 Reactive Dyes And Preparations Based
32    32041600                                                    1,079.40        31.07%
                 Thereon

                 Polyethylene having a specific gravity of
33    39011000                                                    1,073.70        31.07%
                 less than 0.94

34    7031019    Onions, Fresh Or Chilled, Nes                    1,072.91         0%

                 Combed Single Cotton Yarn, With >=85%
35    52052100                                                    1,048.67        37.07%
                 Cotton, Nprs,>=714.29 Decitex(<=14mn

                 Flat Knitting Machines; Stitch-Bonding
36    84472000                                                    1,040.97        11.12%
                 Machines

                 Unbleached Plain Woven Fabrics Of
37    52081100                                                    1,026.36        89.42%
                 Cotton With>=85%Cotton, =<100g/M2

                 Polyvinyl Chloride, Not Mixed With Other
38    39041000                                                     954.88         31.07%
                 Substances, In Primary Forms

39    7134090    Dried Lentils, Shelled, Nes                       938.05          0%

                 Coloured Denim, With <85% Cotton,
40    52114200                                                     874.12         89.42%
                 >200g/M2

41    7132090    Dried Chickpeas (Garbanzos) Shelled, Nes          826.24          0%


42    31042000   Potassium Chloride                                825.21          0%




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Annexure: Trade data and brief analysis — Slide 4 PDF page 89

SL                                                            LC Value
      HS CODE               Commodity Name                                      TTI
No.                                                        (USD in Millions)

43    60011000   Long Pile Fabrics, Knitted Or Crocheted        825.21         89.42%

                 Coloured Plain Cotton Woven Fabrics
44    52084200                                                  806.50         89.42%
                 With >=85% Cotton, >100g/M2

                 Other Maize, Excluding wrapped/canned
45    10059090                                                  802.35           5%
                 upto 2.5 kg
                 Piston      Engine,Capacity>50cc not
46    87112021   >250cc,Motorcycle,In CKD with four             781.91         89.42%
                 stroke engine
                 Dyed Woven Cotton Fabrics, With >=85%
47    52093900                                                  779.32         89.42%
                 Cotton, >=200g/M2, Nes

                 Generating Sets With Compression-
48    85021300                                                  770.07         26.27%
                 Ignition Engines, >375 Kva

                 Multiple Or Cabled Yarn, >=85% Acrylic
49    55093200                                                  745.21         37.07%
                 Or Modacrylic Staple Fibres, Nprs
                 Recond.Motor         Cars        &oth.
50    87032211   Vehicles,incl.stn.        wagons,CBU,          732.17         127.84%
                 cap.>1000cc,but=<1500cc

51    79011190   Zinc, Not Alloyed, >=99.99% Pure, Nes          723.53         31.07%


52    54023300   Textured Yarn of Polyezster                    721.07         58.69%

                 Milk & cream in powd,gran or oth. solid
53    4022191    form fat..exceed1.5% imp by VAT                717.65         37.07%
                 reg.Milk&pr
                 Dyed 3 Or 4-Thread Twill (Incl. Cross
54    52093200                                                  710.33         89.42%
                 Twill), With >=85% Cotton
                 Com.Sin.Cot.Yarn,With>=85%Cot.,Nprs,
55    52052400   <192.31de.But>=125de>52mn                      709.19         37.07%
                 But<=80mn

56    54011000   Sewing Thread Of Synthetic Filaments           701.87         37.07%


57    84522100   Automatic Sewing Machines                      677.77         26.27%




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Annexure: Trade data and brief analysis — Slide 5 PDF page 90

SL                                                                LC Value
      HS CODE               Commodity Name                                          TTI
No.                                                            (USD in Millions)
                 Other Paper & P.Board,Multiply Paper &
58    48109200                                                      673.83         58.69%
                 Paperboard
                 Uncombed
59    52051100   Sin.Cot.Yarn,With>=85%Cot.,Nprs,=>714              669.69         37.07%
                 .29 Decitex (<=14mn).

60    27111300   Butanes, Liquefied                                 652.45         7.07%

                 Semi- Or Bleached Non-Coniferous
61    47032900                                                      650.06         5.07%
                 Chemical Wood Pulp, Soda..., Nes

                 Finishing Agents Etc. Of A Kind Used In
62    38099100                                                      647.41         31.07%
                 The Textile Or Like Industries Nes

63    7131090    Dried Peas Shelled, Nes                            643.60           0%


64    76011000   Unwrought Aluminium, Not Alloyed                   607.45         31.07%

                 Synthetic Staple Fibres, Of Polyesters, Not
65    55032000                                                      596.96         10.32%
                 Carded, Combed Or Processed

                 Cathodes And Sections Of Cathodes Of
66    74031100                                                      571.05         31.07%
                 Refined Copper

67    84118200   Gas Turbines, Of A Power >5000kw                   567.90         26.27%

                 Com.Sin.Cot.Yarn,With>=85%Cot.,Nprs,
68    52052300   <232.56deci(>43mm)But>=192.31de(<=5                566.94         37.07%
                 2mn
                 Dyed Plain Cotton Woven Fabrics With
69    52083100                                                      561.76         89.42%
                 >=85% Cotton, =<100g/M2

                 Washing, Bleaching Or Dyeing Machines,
70    84514000                                                      554.40         26.27%
                 Nes

71    8081090    Apples, Fresh, Nes                                 539.49         89.42%

                 Semi-Products Of Iron Or Non-Alloy
72    72072000                                                      512.69         844.08%
                 Steel, >=0.25% Carbon

                 Other reception, transmission app.(excl.
73    85176290                                                      481.26         58.69%
                 modem, telephonic/telegraphic switch.



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Annexure: Trade data and brief analysis — Slide 6 PDF page 91

SL                                                                LC Value
      HS CODE               Commodity Name                                              TTI
No.                                                            (USD in Millions)
                 Parts      Of       Aircraft         (Excl.
74    88039000                                                      462.54             5.07%
                 Aeroplanes/Helicopters)

                 Yarn, <85% Acrylic Or Modacrylic Staple
75    55096200                                                      456.73             37.07%
                 Fibres, Mixed With Cotton, Nprs

                 Lubricationg oil,that is oil such as is not
76    27101921                                                      454.88             49.08%
                 ordinarly used..below 220 f.., tv
                 polyacetals, other polyethers and epoxide
      39076090   resins, in primary forms; polycarbonates,                             24.99%
77                                                                  454.71
      39076990   alkyd resins, polyallylesters and other                               26.07%
                 polyesters, in primary forms --> other
                                                                                   N/A, (87042217-
                 Motor Vehicles for the transport of goods-                           37.06%,
78    87042219                                                      453.79
                 > Other, CBU                                                        87042216-
                                                                                      58.69%)
                 Weaving Machines For Weaving Fabrics,
79    84463000                                                      447.83             11.12%
                 >30cm Wide, Shuttleless Type

80    84798900   Machines, having individual functions, nes         444.88             26.27%

                 Ferrous Products Obtained By Direct                               1,000 BDT/MT +
81    72031000                                                      442.55
                 Reduction Of Iron Ore, In Lumps...                                800 BDT/MT 4%

                 Crude palm oil imported by VAT
82    15111010                                                      431.30             32.07%
                 registered edible oil refinery industries
                 Portable Digital AdpMachines,Wt<=10
83    84713000   Kg,Comp.At                     Least               427.19               5%
                 Cpu,Keyboard&Display
                 Machines For Wringing, Dressing,
84    84518000                                                      424.54             26.27%
                 Finishing... Textile Yarns, Fabrics...
                 Machinery                               For
85    84223000   Filling,Closing...Etc.Bottles,CansEtc,&            417.23             26.27%
                 Aerating Drinks
                 Dyed Woven Cotton Fabrics, With >=85%
86    52083900                                                      409.51             89.42%
                 Cotton, Nes
                 Milk And Cream In Solid Forms Of
87    4021091    =<1.5% FAT imported by vat reg. Milk               400.77             37.07%
                 and




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Annexure: Trade data and brief analysis — Slide 7 PDF page 92

SL                                                               LC Value
      HS CODE               Commodity Name                                         TTI
No.                                                           (USD in Millions)

88    89061000   Warships                                          397.42         31.07%


89    84452000   Textile Spinning Machines                         380.29         11.12%

                 Limestone flux;Limestone      and other
                 calcareous stones,of a kind used for the
                 manufacture of lime or cement -->
90    25210000                                                     370.75         68.89%
                 limestone flux;limestone      and other
                 calcareous stones,of a kind used for the
                 manufacture of lime or cement
                 Generating sets with spark-ignition
91    85022000                                                     370.36         26.27%
                 internal combustion piston engines

92    28362000   Disodium Carbonate                                355.03         31.07%

                 Artificial Staple Fibres, Of Viscose
93    55041000                                                     351.16         10.32%
                 Rayon,NotCarded,Combed Or Processed

                 Insecticides For Dairy,     Poultry   and
94    38089110                                                     349.92          10%
                 Agricultural purposes

                 Semi-Products Of Iron Or Non-Alloy
95    72071900                                                     349.60         844.08%
                 Steel, <0.25% Carbon, Nes

                 Durum      wheat      Seed,        EXCL.
96    10011190                                                     348.29           0%
                 Wrapped/canned upto 2.5 Kg
                 Petroleum Oils And Oils Obtained From
                 Bituminous Minerals,Other Than Crude;
                 Preparations Not Elsewhere Specified Or
                 Included,Containing By Weight 70% Or
      27101200
97               More Of Petroleum Oils Or Of Oils                 347.90         86.42%
      27101239
                 Obtained           From         Bituminous
                 Minerals,These Oils Being The Basic
                 Constituents Of The Preparation;Waste
                 Oils --> Light oils & preparations.
                 Looped Pile Fabrics Of Cotton, Knitted Or
98    60012100                                                     345.69         89.42%
                 Crocheted

99    52030000   Cotton, Carded Or Combed                          336.91         26.07%




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Annexure: Trade data and brief analysis — Slide 8 PDF page 93

SL                                                               LC Value
      HS CODE                 Commodity Name                                          TTI
No.                                                           (USD in Millions)
                    Unbleached Kraftliner, Uncoated Paper &
100    48041100                                                    334.92            37.07%
                    Paperboard In Rolls Or Sheets

        Total:                                                  132,110.16

  Source: Bangladesh Bank Dashboard

  The table is an indication that zero tax, low tax and high tax goods are vulnerable to be
  abused for TBML. Goods imported in huge/bulk amounts are also vulnerable in this
  context.
  a) In the table above we can see that the duty of the cane sugar (H.S Code 1701.14.00)
     imported during 2013-2017 was BDT 2000, whereas the same type of cane sugar (H.S
     Code 1701.99.00, 1701.91.00) in which import/customs duty was BDT 4500 was either
     not imported or was reported as the H.S Code bearing low import duty.
  b) Instances are there where even though HS Code was reported correctly price was quoted
     so low (e.g USD 1.00 for hair drier) that market never justifies and the motive of which
     was obviously to evade tax.
  c) In some cases it has been found that price of the goods like Maize (H.S Code 10059090)
     imported from China during 2017 ranged from USD 186 to 218 Per MT; the same goods
     imported from Brazil also ranged from $184 to $222, and the ones imported from India
     ranged from $210(March 2018) to $252 (Jan 2018). There are also examples where we
     can see that a customer imported same goods (H.S Code 1302.32.00 for example) from
     the same country at a price of $3.79/kg in January, 2018 and at a price of $37.55/kg in
     February, 2018. Though in the later case the import was made through air the price was
     significantly higher. On 1st January, 2017 while importing Onions (HS Code 0703.10.19)
     from India price ranged from $130 to $350 and the import duty was 0%. In importing
     Looped Pile Fabrics of Cotton, Knitted or Crocheted (HS Code 60012100,) from same
     country and during the same week price fluctuated tremendously though TTI was
     89.42%. There are ample evidences that price fluctuated significantly while importing
     goods bearing no duty, less duty and high duty (where importer doesn’t bother for tax and
     his motive is to siphon money). Therefore, even before access to a combined database by
     the banks, they should conduct due diligence establishing and analyzing their own
     database.
  d) During 2016-2017 in some cases it was found that freight charges in the import of fruits
     like apple ranged from around 26% to 55% of FOB Value. This sort of abnormality
     should trigger TBML Alert and entails due diligence on the part of the bankers.
  e) There are huge number of low value cases where under no commercial value goods are
     imported which should trigger alerts and entail due diligence on the part of the customs



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Annexure: Trade data and brief analysis — Slide 9 PDF page 94

   officials. Before endorsing these type of documents bankers should conduct CDD. As
   import is conducted though LCAF without opening LC, caution should be taken in these
   sorts of cases by bank officials through proper KYC.
f) In some cases it has been seen that some EPZ companies were importing goods
   (industrial salt etc. for example) from local suppliers and were again exporting to local
   traders, lack of justification of which triggers alert.



Some of the factors derived from analysis of export data of several years:
a) Higher percentage of cash incentive contributes to boosting certain export goods. These
   goods are vulnerable to be over invoiced as more proceeds ensure more cash incentive to
   the exporters.
b) To ensure a stable forex reserve, exporter is not barred by the regulators to export even
   for failure to repatriate export proceeds in time (within 4 months). Some exporters have
   been seen to take advantage of this and continue exporting to same country/beneficiary
   for a few years even though most of the proceeds were not realized. Non-repatriation or
   even long delay in repatriation may increase vulnerability to TBML.
c) Sometimes it has been seen that during the same period and within the same market
   products with same features and quality have significant differences in price.
d) Use and import of old machineries by the exporters to produce export goods triggers
   TBML alert.
e) Irregular products or commodities prices of which are not easily available are vulnerable
   to TBML.




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Guidelines for Prevention of Trade Based Money Laundering
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