Import-Export Company

Local importers utilize the peso broker to obtain U.S. dollars outside official channels, paying the broker with local currency. The broker then settles the importers’ invoices using illicit funds disguised as normal trade payments. Financial institutions struggle to identify suspicious flows when the transactions are supported by legitimate-looking documentation and shipping records.

• Facilitates cross-border transactions by issuing invoices and shipping documents, often for the same goods repeatedly moved among related entities.
• Enables the submission of VAT refund claims that far surpass actual commercial activity, complicating financial institutions' ability to verify legitimate trade.
• May be fully controlled or infiltrated by criminals exploiting tax systems across multiple jurisdictions.

Import-export companies are used as fronts for smuggling operations by:

• Concealing illicit tobacco products among legitimate goods, complicating risk assessments by financial institutions.
• Submitting trade documentation that appears legitimate yet obscures the true nature and value of shipments.
• Blurring the line between lawful exports and contraband flows.

Import-export companies, whether knowingly or unwittingly, facilitate round-tripping by:

• Issuing repeated invoices or shipping documents for the same goods (such as diamonds), thereby creating artificial circular flows.
• Producing transaction records that lack genuine economic activity, which complicates financial institutions' monitoring of beneficial ownership.

Import-export companies, whether complicit or unwitting, oversee cross-border transactions and customs paperwork. Criminals exploit these entities by:

• Mixing illicit goods with regular consignments, masking the true nature or value of shipments.
• Presenting payments to financial institutions as routine trade transactions, making it harder to detect the illicit source of funds.

Import-export companies facilitate the laundering of commodity trafficking proceeds by commingling illicit and legitimate trade.

• Fraudulent shipping records, inflated invoices, or misdeclared goods obscure the trail of illicit funds.
• Financial institutions find it difficult to validate trade authenticity when documentation is altered or missing.

Such firms—real or fabricated—manage cross-border commodity trades where prices and shipping details are manipulated. They obscure the origin and value of goods, complicating financial institutions' efforts to identify suspicious transactions in trade finance.

Engages in cross-border trade, handling customs paperwork and shipping logistics that can be manipulated to disguise counterfeit stock.

• May file falsified declarations or invoices, masking the true contents of shipments and the origin of goods.
• Presents challenges for financial institutions attempting to verify legitimate trade transactions or track the flow of funds tied to imports and exports.

Import-export companies, including trade intermediaries and shipping or logistics providers, facilitate countertrade by:

• Coordinating the movement of goods with ambiguous or volatile market values, such as tires or gasoline.
• Allowing repeated or recycled shipments, sometimes left unclaimed, which muddy transactional records.
• Generating layered documentation that complicates financial institutions’ attempts to distinguish legitimate trade from concealed illicit flows.

Import-export companies are leveraged to:

• Present inflated or fictitious shipments or invoice values that justify cross-border transactions.
• Provide a veneer of legitimate international trade, limiting scrutiny from financial institutions.

These companies allow criminals to obscure underlying illicit activity behind ordinary commercial trading channels.

Import-export companies are used to handle cross-border diamond shipments:

• Criminals exploit these businesses to submit repeated or inflated invoices, re-valuing diamonds at each stage.
• Complex shipping routes and staged documentation obscure the origin of illicit funds, hindering financial institutions' due diligence.

Import-export companies knowingly facilitate documentary collection manipulation by submitting or altering shipping documents, such as forged bills of lading, to:

• Conceal or misrepresent the true nature, quantity, or value of goods.
• Present nonexistent or partial shipments as legitimate, causing financial institutions to release funds under false pretenses.

This exploitation undermines the bank’s verification processes, as documentary collection relies heavily on the accuracy of trade paperwork, making it difficult for financial institutions to detect or investigate the true origin of funds.

Import-export companies contribute to trade-based laundering within the drug trade by:

• Masking narcotics shipments among legitimate goods or misrepresenting shipment contents.
• Manipulating invoices (over- or under-invoicing) to transfer illicit drug proceeds under the guise of trade.
• Exploiting international supply chain complexity to evade law enforcement controls.

Import-export companies enable trade-based laundering of natural resources. They:

• File falsified or incomplete invoices to conceal the actual volume or origin of timber, fish, or other resources.
• Legitimize cross-border payments under the appearance of ordinary trade, masking illicit proceeds.
• Serve as cover for shipments of illegally sourced materials, undermining financial institutions’ ability to trace true sources of funds.

Import-export companies knowingly or unknowingly enable overvalued exports by:

• Submitting inflated invoices and shipping documents for cross-border transactions.
• Arranging payments that exceed actual production or market costs, masking illicit gains as legitimate revenue.
• Undermining financial institutions’ ability to verify the true value of goods, as standard checks often rely on provided trade documents.

Import-export companies are used to manipulate invoice values in cross-border transactions by:

• Inflating or understating the declared prices of goods or services.
• Fragmenting payment flows through advanced or partial settlements.
• Presenting a veneer of legitimate trade to disguise illicit funds.

Import-export companies (legitimate, shell, or front) facilitate ghost shipping by:

• Presenting fabricated commercial invoices and bills of lading to financial institutions, purporting to move goods that do not actually exist.
• Reusing or replicating the same paperwork across multiple transactions, artificially inflating trade volumes and layering illicit proceeds.

Their involvement misleads financial institutions into financing or processing payments for nonexistent cargo.

Import-export companies can knowingly or unknowingly facilitate cross-border over-invoicing by:

• Submitting or accepting invoices with values above fair market rates, thus transferring surplus funds.
• Labeling inflated remittances as legitimate trade settlements.

This complicates financial institutions' ability to identify abnormal pricing or potential laundering activities.

• These firms, whether knowingly or unknowingly, submit or receive falsified invoices and shipping documents.
• Mixing legitimate shipments with inflated or fictitious invoices creates the appearance of normal cross-border trade.

Import-export companies facilitate the misrepresentation of fund purposes by:

• Submitting fictitious trade documentation (e.g., invoices, bills of lading) to financial institutions, portraying illicit funds as payments related to shipping or customs.
• Creating a veneer of legitimate cross-border commerce, thus hiding true criminal proceeds behind fabricated import/export activities.

Import-export companies enable multiple invoicing schemes by:

• Submitting identical or slightly modified invoices to various financial institutions for the same shipment.
• Reusing shipping documentation across multiple credit or financing requests, layering illicit proceeds behind legitimate trade transactions.

These practices allow them to extract multiple payments or credit facilities for one actual shipment, complicating financial institutions’ monitoring and due diligence processes.

Criminals use or control an import-export company to:

• Present falsified or inflated export orders, pro forma invoices, and shipping documents when applying for pre-shipment finance.
• Overstate or fabricate the volume and value of goods, concealing the absence or minimal nature of actual shipments.
• Channel illicit funds back as purported export proceeds to repay the financing, embedding criminal cash into legitimate trade flows.

Import-export entities facilitate cross-border trade involving precious metals or gemstones by:

• Managing shipping documents and customs declarations that can be manipulated to overvalue or undervalue shipments.
• Providing a veneer of legitimate trade through which criminals circulate illicit goods across multiple jurisdictions, hindering financial institutions' ability to detect the original illicit source of funds.

Import-export businesses may be exploited to:

• Submit inflated invoices or fabricated purchase orders to receive higher advance payments under red/green clause letters of credit.
• Conceal the actual nature or quantity of goods, allowing illicit proceeds to blend with legitimate trade flows.
• Present falsified trade documents to financial institutions, complicating efforts to verify authenticity and detect laundering.

Import-export companies employ trade-based techniques, such as over- or under-invoicing, to embed illicit proceeds in legitimate commerce. By manipulating trade documents and flows, they conceal sanctioned entities' involvement in cross-border transactions, making it harder for financial institutions to detect and block prohibited activities.

Import-export companies may be complicit or unwittingly involved by:

• Submitting manipulated shipping documents (e.g., inflated invoices) to financial institutions.
• Claiming legitimate trade operations while disguising or inflating the value and quantity of goods.

This tactic obscures the movement of illicit funds within cross-border transactions, complicating banks' verification processes.

Import-export companies act as the borrowers in syndicated trade loans by:

• Presenting over-inflated invoices or phantom shipments to obtain higher loan amounts.
• Exploiting partial scrutiny among co-lenders, who rely on the lead arranger’s due diligence.
• Obscuring actual ownership and transaction values, thereby layering illicit proceeds through multiple lending channels.

Import-export companies can be complicit or controlled by perpetrators who overstate export values to qualify for unwarranted rebates. These distorted trade figures complicate financial institutions' due diligence on cross-border transactions, as the documentation may appear authentic while concealing falsified or inflated export revenues.

Import-export companies, including those acting as trade intermediaries, facilitate trade diversion by:

• Routing shipments through multiple jurisdictions and producing or accepting misleading trade documentation.
• Allowing transactions that closely mimic legitimate commercial operations, making suspicious activity harder for financial institutions to detect.

Import-export companies facilitate trade misinvoicing by:

• Submitting invoices with falsified values or product descriptions, knowingly or unknowingly aiding in the layering of illicit funds.
• Providing documentation that can deviate significantly from actual shipments, complicating banks' and trade finance institutions' ability to verify transaction legitimacy.

Import-export companies are used or established (knowingly or unknowingly) to:

• Move goods across borders under misrepresented documentation, concealing or inflating cargo value.
• Justify cross-border payments tied to inconsistent invoices, complicating financial institutions’ ability to identify trade irregularities.
• Facilitate rapid shifts in shipping routes and volumes, reducing transparency and creating discrepancies between actual and declared trade activity.

Import-export companies serve as front businesses for unlicensed MSBs by:

• Allowing illicit proceeds to mingle with legitimate trade revenues, making it harder to trace funds.
• Concealing beneficial ownership behind normal commercial activities, complicating financial institutions' ability to detect suspicious transactions.