Multiple Invoicing

Criminals issue more than one invoice covering the same goods or services, relying on repeated or duplicated billing to extract multiple payments, loans, or letters of credit from different financial institutions. They may also reuse identical or slightly amended supporting documents (such as shipping records) to reinforce the legitimacy of these parallel invoices. By doing so, they layer illicit proceeds under normal-looking trade settlements, complicating oversight and obscuring the money trail. In many cases, there is no need to alter the invoiced price: simply submitting the same invoice multiple times to separate lenders or banks can suffice. This further compounds the risks associated with invoice manipulation, and it can be combined with tactics such as over- or under-invoicing and ghost shipments to exploit gaps in trade finance checks.

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Code
T0008.001
]
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Name
Multiple Invoicing
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Version
1.0
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Parent Technique
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Tactics
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Risk
Product Risk
]
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Created
2025-02-24
]
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Modified
2025-04-02
]

Double Invoicing

Tactics

ML.TA0007
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Criminals use repeated or duplicated invoicing to generate multiple transaction records under normal trade finance processes. This obscures the audit trail and distances illicit proceeds from their criminal origin.

Risks

RS0002
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Product Risk
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By duplicating documentation within trade finance, criminals can extract multiple credit or payment streams, obscuring the underlying financial flows.

Indicators

IND00859
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Multiple invoices for the same shipment or service with identical or near-identical details (e.g., item description, quantity, value) but carrying distinct invoice references, suggesting repeated billing for the same transaction.

IND00985
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Invoices exhibit sequential numbering or issuance timestamps indicating they were generated in quick succession for the same shipment or service.

IND00986
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Multiple beneficiary bank accounts or financial institutions indicated on invoices for the same shipment or service, suggesting potential layering or diversion of funds.

IND00987
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Beneficiary entity’s historical records show repeated issuance of duplicate or overlapping invoices across multiple transactions.

IND02414
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Invoices that do not match the actual shipped value or quantity for the referenced goods or services, indicating potential misrepresentation of transaction details.

IND02416
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Frequent amendments or replacements of invoices for the same shipment or service, lacking legitimate business explanations.

IND02418
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Multiple separate financial institutions involved in financing the same shipment or service, enabling duplicated financing requests.

IND02420
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Mismatches between shipping documents and invoice details (e.g., goods quantity, type, or shipping dates) for the same transaction.

IND02421
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Complex or layered trade finance arrangements that deviate from the customer’s typical business patterns or scale of operations.

IND02422
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Customer offers contradictory or vague justifications for issuing multiple invoices covering the same shipment or service.

IND02424
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Invoices repeatedly originate from entities in high-risk or weakly regulated jurisdictions, raising concerns of limited oversight.

IND02426
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Multiple trade finance instruments, such as letters of credit, simultaneously issued against the same underlying goods or services.

IND02427
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Involvement of entities with no verifiable commercial operations or minimal corporate presence in the invoicing process.

IND02428
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Repeated usage of identical shipping or logistics reference numbers in documentation for multiple distinct invoices, indicating potential duplication of trade flows.

Data Sources

Compiles risk profiles of different jurisdictions and helps flag invoices originating from high-risk or weakly regulated regions. This supports enhanced scrutiny of repeated invoicing tied to high-risk areas.

Provides invoice identifiers, amounts, payment terms, parties involved, and related details. This data is crucial for identifying duplicated or overlapping invoices, verifying consistent beneficiary information, and detecting repeated billing for the same goods or services.

Captures transaction timestamps, amounts, currencies, and involved parties. By reviewing these logs, investigators can identify multiple payments or disbursements for the same goods or services, revealing repeated billing patterns suggestive of multiple invoicing.

Contains ownership details, account types, balances, and transaction histories. This information helps identify multiple accounts receiving payments for the same shipment or service, highlighting potential layering or repeated financing under multiple invoicing schemes.

Holds information on a company’s operational practices, revenues, and typical transaction volume. This data allows for the detection of repeated invoicing beyond normal business activity or scale, indicating potential abuse of trade finance arrangements.

Documents details of credit lines, loan amounts, and collateral. By reviewing these records, one can detect overlapping or simultaneous financing instruments (e.g., multiple letters of credit) tied to the same underlying goods, revealing repeated invoice submissions.

Encompasses shipping records, manifests, bills of lading, and related logistical documents, allowing direct comparison of declared goods and services against invoiced details. This data helps confirm whether shipments are actually duplicated or whether reference numbers are reused to support multiple billings.

Contains verified identities, beneficial ownership details, and overall risk assessments. Reviewing these records helps identify contradictory explanations for repeated invoices, detect shell or front entities, and support further investigation of suspicious billing patterns.

Details cross-border payment flows, correspondent banking relationships, and participating financial entities. This data helps identify overlapping financing of the same shipment or services through different institutions, which is a key indicator of multiple invoicing activity.

Offers official details on corporate registration, ownership structures, and key principals. This data is vital for verifying whether entities issuing repeated invoices have legitimate commercial operations or are shell companies used to create multiple billing layers.

Mitigations

Apply deeper scrutiny to trade finance clients suspected of duplicating invoices. Verify the authenticity and consistency of submitted shipping, logistics, and payment records, ensuring each invoice corresponds to a distinct shipment or service. Utilize third-party data or shipping confirmations to confirm actual cargo volumes, shipping schedules, and transaction legitimacy, preventing multiple repayments or letters of credit for the same goods.

Configure specialized monitoring rules to detect concurrent or repeated invoice payments referencing the same shipment or service. For instance, generate alerts when multiple payments from different sources cite near-identical invoice numbers, values, or shipping data. Investigate scenarios where a single customer or related entity presents the same invoice to multiple financial institutions, signaling potential layered financing through multiple invoicing.

Provide trade finance teams with focused training on spotting red flags of multiple invoicing, such as identical invoice details presented to multiple lenders, repeated shipping references, or contradictory shipping schedules. Instruct staff on the importance of cross-verifying transaction documents and escalating suspicious invoice duplication to compliance teams for immediate review.

Cross-reference invoice details—such as shipping references, vessel identification, or logistics providers—with external registries and publicly available data. Detect patterns of repeated document usage, shipping routes, or cargo descriptions across multiple invoices. This verification approach exposes duplicative or overlapping references that support multiple invoicing schemes.

Implement robust trade finance monitoring that cross-checks invoice references, shipping documentation, and supporting evidence for duplication or overlap. Specifically, flag repeat usage of identical invoice details, shipping references, or goods descriptions that might indicate multiple invoicing for the same transaction. Analyze commodity volumes, shipping routes, and timelines to confirm transactions are legitimate and not being financed multiple times.

Instruments

Criminals seek multiple letters of credit from different financial institutions using the same invoice and accompanying trade documents. Each bank assumes it is guaranteeing payment for a separate transaction. The legitimizing effect of a letter of credit conceals that the goods or services are actually financed multiple times under the same shipment, layering illicit funds behind seemingly normal trade finance.

Criminals reuse or slightly amend trade-related documents such as shipping records, bills of lading, and other instruments. By presenting these documents to various financiers or banks, each believes it is financing a distinct shipment. The inherent reliance on documentary evidence in trade finance allows the layering of illicit proceeds through repeated or parallel claims against the same goods or services.

Criminals issue multiple bills of exchange referencing the same shipment or service. Each bill obligates a payer to settle amounts that, in reality, have already been financed or paid elsewhere. This replication allows them to draw funding from several banks, obscuring the original transaction and accumulating multiple streams of illicit revenue.

Criminals repeatedly sell or pledge the same invoice to multiple lenders or financiers. By issuing duplicate invoices for an identical shipment or service, they convert a single receivable into multiple funding streams. The ease of replicating or slightly modifying invoice details (e.g., references, amounts) makes accounts receivable highly vulnerable to layered financing in multiple invoicing schemes.

Service & Products

  • Criminals reuse duplicate or nearly identical shipping and invoice documents for the same goods, presenting them to different banks for collection.
  • Each bank processes what appears to be a legitimate trade transaction, resulting in multiple payments for one actual shipment.
  • Automated or outsourced invoice systems can be misused to create numerous legitimate-looking copies of the same invoice.
  • These duplicates are then presented to separate payers or financiers, concealing repeated billing for the same goods or services.
  • By submitting the same invoice or shipping records to different banks, criminals can secure multiple letters of credit for a single shipment.
  • Repeated issuances of letters of credit for one set of goods obscure the money trail and enable compounding illicit proceeds.
  • Criminals reuse or slightly amend the same invoice and supporting documentation to secure repeated credit or settlement across multiple trade finance arrangements.
  • This tactic layers illicit funds behind legitimate-appearing trade deals, making detection more difficult for financial institutions and regulators.
  • The same invoice or shipping documentation is presented as collateral for loans from multiple lenders.
  • By layering these credit applications, criminals obtain several loans for a single set of goods or services, effectively multiplying illicit proceeds.
  • Criminals present identical or slightly altered invoices to various supply chain finance providers, each believing they are financing separate transactions.
  • Multiple parallel financing streams are generated off the same shipment or service, layering illicit money under legitimate supply chain operations.
  • The same receivable or invoice is factored multiple times with different lenders, each unaware that the claim has already been financed elsewhere.
  • This creates parallel revenue streams on one underlying transaction, hiding illicit earnings under ordinary business receivables.

Actors

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.

Illicit operators execute multiple invoicing schemes by issuing repeated or slightly amended invoices for the same goods or services. This enables them to obtain multiple financing or credit lines from different financial institutions, layering illicit funds under normal trade transactions. By reusing supporting documents, they obscure the true nature of the deals and hamper detection efforts.

Financial institutions are exploited when:

  • Criminals present separate but identical invoices to different branches or departments, each believing it is financing a distinct transaction.
  • Letters of credit, loans, or other credit lines are approved based on duplicate trade documentation, unwittingly funding a single shipment multiple times.

This fragmentation among multiple financial providers obscures the money trail and amplifies the layering of illicit proceeds.

References

  1. Hataley, T. (2020). Trade-based money laundering: organized crime, learning and international trade. Journal of Money Laundering Control Vol. 23 No. 3, pp. 651-661. https://doi.org/10.1108/JMLC-01-2020-0004

  2. Makkink I.M, Steyn B., Bezuidenhout H.C. (2024). The role of freight forwarding companies in detecting and investigating trade-based money laundering. Journal of Money Laundering Control. https://www.emerald.com/insight/content/doi/10.1108/jmlc-04-2024-0069/full/html

  3. Sivaguru, D. (2023). The phenomenon of trade-based money laundering (TBML) – a critical review in Sri Lankan context. Journal of Money Laundering Control, Vol. 26 No. 6, pp. 1088-1099. https://doi.org/10.1108/JMLC-10-2022-0151