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Best Practices for Countering Trade-Based Money Laundering

D AML/CFT INDUSTRY PARTNERSHIP Best Practices for Countering trade Based Money Laundering May 2018 Best Practices on trade finance Page 1 of 37 Contents 1. Introduction .. 2 Background .. 2 Objectives .. 2 Methodology .. 2 Terminology .. 3 Scope .. 3 2. Governance and Management Oversight .. 3 Risk 3 Roles and Responsibilities .. 6 Management Oversight in trade finance .. 8 Independent Assurance and Testing .. 9 Internal Reporting and Role of Compliance Officer or MLRO .. 10 3. Due Diligence .. 11 Policies and Procedures.

The Wolfsberg Group, ICC and BAFT - Trade Finance Principles (2017) 5 FATF Guidance for a Risk-Based Approach – the Banking Sector (October 2014) 6 FATF Guidance on National Money Laundering and Terrorist Financing Risk Assessment (February 2013)

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