IMPORT–EXPORT · CROSS-BORDER TRANSACTIONS
A starting point for businesses and professional advisers involved in international trade. Trading across borders does not, on its own, make a business an AML obliged entity.
FOUR DISTINCT QUESTIONS
A discrepancy is a question to examine in context, not automatic evidence of wrongdoing.
Goods, economic purpose and actual counterparties.
Contract, invoice, transport and customs records, where relevant.
Who pays and receives, when, and through which institutions.
Applicable country, party and goods restrictions.
WHEN A CLOSER REVIEW MAY HELP
Goods descriptions, price, parties or dates cannot be readily reconciled. FATF indicators call for contextual assessment rather than automatic conclusions.
A bank asks about source of funds, the role of a counterparty or economic rationale. A verifiable response helps reduce ambiguity and repeated requests.
AML, sanctions and customs requirements have different sources and responsible parties. The applicable regime depends on the goods, country and people involved.
RECONCILING THE TRADE CHAIN
The useful signal is often not in one document: it emerges when price, movement of goods, parties and payment no longer describe the same transaction.
WHEN THE TRADE CHAIN DOES NOT RECONCILE
A useful review connects goods, counterparties, prices, documents and financial flows before drawing conclusions.
Invoice and contract identify one customer, but funds arrive from another company or jurisdiction.
Value, goods description, transport or countries involved contain inconsistencies that may look minor in isolation.
An intermediary pauses or reviews a payment and asks for UBO, contracts, invoices, source of funds or flow explanations.
Trade-based money laundering indicators are risk signals to assess together and in context.
A REAL CASE, A PRACTICAL QUESTION
On 30 June 2026, EPPO reported preventive freezing of textiles worth approximately €11 million in Prato. In the China-import investigation, altered transport records and false invoices allegedly regularised goods through fictitious transactions involving companies in several EU states. This is not a conviction.
What to checkDo origin, importer, actual recipient, warehouse, declared value and account paid describe the same transaction? A later invoice does not by itself resolve an inconsistency in the original route: establish what each document actually proves.
Reconstruct the transaction and evidence →On 22 July 2026, EPPO announced ten convictions by the Tribunal of Nola for VAT fraud and related offences in plastics trading. The reported scheme involved shell companies and invoices for non-existent transactions. Sentences remain appealable; proceedings against two additional defendants continue.
What to checkDoes the supplier have operational capacity? Can deliveries, margins and payment routes be reconciled? The objective is not more invoices: establish that intermediaries and transactions have a corroborable economic role.
Support for firms advising the supply chain →Cases reflect the status reported in the cited release. Practical questions are professional applications: no indicator alone establishes wrongdoing or automatically determines reporting, refusal or approval of a transaction.
SCOPE OF SUPPORT
I can help reconstruct the parties, purpose and flows, identify missing information and coordinate responses to an institution’s AML questions.
Boundary: AML advisory does not replace specialist customs or legal advice, guarantee the outcome of a transaction or override applicable restrictions.
Output to agree: a map of parties and flows, a list of inconsistencies or missing information, and a response outline.
SOURCES AND STATUS · 21 SEPTEMBER 2026
FATF indicators are signals to assess, not standalone duties for every business. Sanctions and customs rules depend on the facts and must be checked against the applicable current instruments.
