Trade-based money laundering moves value by misstating what was shipped: the price, the quantity or the goods themselves. The payment is ordinary. The story behind it is not.

FATF has described the typology for years: over-invoicing moves value to the seller, under-invoicing moves it to the buyer, and phantom shipments move it with no goods at all. The techniques are well known. They are still hard to see from a payments queue.

Why monitoring misses it

Transaction monitoring looks at money. A wire to a freight forwarder in a familiar corridor, for an amount close to the customer's usual payments, raises nothing. The rule has no idea what the wire paid for.

The documents that would tell it are usually somewhere else: attached to a trade finance file, stored by the relationship manager, or never collected at all for open-account trade. The signal exists. It sits in a different system from the alert.

Where the signal sits

A wire of $48,300 to a freight forwarder raises nothing on its own. Read against the invoice, the bill of lading and the customer's declared business, it can: a unit price far above market, a route that doubles back, a consignee that shares a director with the buyer.

None of those facts is proof. Prices vary, routes change for good reasons, and small trading communities share directors. Each one is a question that the documents can usually answer, if someone reads them next to the payment.

Trade customers also tend to have long, regular histories. That is useful. A customer that has bought the same goods from the same supplier at a steady price for two years gives a clear baseline, and a break in that baseline is easier to see than any single number on its own.

What an agent compares

Tipline's triage agent pulls the trade documents attached to the payment and checks them against the customer profile and 24 months of activity. Price outliers, circular routes and shared directors are grouped into one finding, each with its source.

• Unit price against the customer's own history for the same goods.

• Quantity and weight on the invoice against the bill of lading.

• Goods described against the customer's declared line of business.

• Route: origin, transshipment points and final destination.

• Parties: shared directors or addresses between buyer, seller and consignee.

• Payment: third-party payers, or payment from a country not on the route.

Where a document is missing, the finding says so. A wire with no invoice on file is not cleared on the strength of the amount.

A pattern, not a transaction

One odd invoice is rarely a case. The pattern matters: the same counterparty, the same inflated unit price, the same route, month after month. Grouping by counterparty over 24 months turns six unremarkable wires into one finding with a trend line.

The same grouping often links trade cases to other alerts. A buyer that overpays a supplier abroad may also be depositing cash at home. The agent places those alerts in the same case, so the analyst sees the whole customer rather than one corridor.

Getting the documents in

None of this works without the documents. For letters of credit and documentary collections, the invoice and the bill of lading are already in the trade finance file, and the agent reads them there. For open-account trade, where the bank only sees the payment, they often are not.

Many banks now ask for an invoice reference in the payment instruction for higher-risk corridors and goods, and request the documents only when a payment falls outside the customer's usual pattern. That keeps the request rare and the reason clear. The agent tracks which payments have documents on file and which do not, so the gap itself becomes visible in the case rather than hidden by it. A corridor where half the payments arrive without documents is a finding in its own right, for the relationship manager as much as for compliance.

What stays with the analyst

The agent never decides that a shipment is fake. It shows the gaps between the documents and the money, and an analyst decides whether they explain themselves.

Often they do. A price spike matches a market shortage, a detour matches a closed port. The analyst records the explanation and closes the finding, and the reason stays on file for the next time the same pattern appears. When they do not, the case moves to escalation with the documents already attached.

What to do on Monday

List your ten largest trade customers by payment volume. For each, check whether invoices and transport documents for last quarter's payments are on file and searchable. If they are not, that gap comes before any rule, model or agent: there is nothing to compare.