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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 .. 11 Identifying the Customer for the Application of Due Diligence Measures.

1 Guidance on Anti-Money Laundering and Countering the Financing of Terrorism Controls in Trade Finance and Correspondent Banking 2 The Wolfsberg Group, ICC and BAFT - Trade Finance Principles (2017) Best Practices on Trade Finance Page 3 of 37 1.4. TERMINOLOGY

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