Trade Based Money Laundering in North America
Focused on understanding and tackling TBML, especially linked to Chinese professional laundering.
About
Trade Based Financial Crime and Money Laundering continues to be likely the most important but least well understood predicate type and money laundering method. The GCFFC MENA chapter has published work in this area already and GCFFC Africa (SSA) is currently considering it for that region. The GCFFC Americas chapter has highlighted the need to focus on this topic because it is intrinsically linked to serious financial and organised crime including drug trafficking (including fentanyl), and professional money laundering, particularly Chinese professional money laundering.
North America (Canada, USA, and Mexico) faces substantial exposure both to trade and to ML due to its large and interconnected economies, cross-border trade and onward trade, and large financial flows. FATF and domestic regulatory agencies such as the US FinCEN have flagged TBML as a critical issue in their reports and advisories, as well as in US AML risk assessments, which call out Chinese Professional Money Laundering.
The new US administration is placing fentanyl trafficking as a key issue and looking for ways to tackle this aggressively, which has increased its importance in both Canada and Mexico, and beyond—particularly in countries related to the supply chain and the ML activity, including China.
Key Priorities:
Understanding Modern TBFC in North America: Identify key corridors and sectors prone to misuse, and assess how criminal organisations exploit trade (including e-commerce and services) to launder proceeds.
Collaboration with FinCEN and Stakeholders: Support FinCEN’s data-sharing efforts and coordinate with FINTRAC and other key stakeholders.
Enhancing Data Analytics and Training: Develop risk assessment tools and red flag identification training for FIs, using materials from Wolfsberg Group, FATF, GCFFC MENA, and GFI.
Engagement with GFI and Research Institutions: Collaborate with GFI to access trade mis-invoicing data.
Outreach and Public-Private Partnership (PPP): Raise awareness and align policy recommendations with private sector needs.
Report: Final Report with Policy Recommendations expected by September 2026.