Inflated Transaction Pricing

Illicit funds are concealed by inflating the prices of goods or services, generating excess amounts that can be diverted for bribery, kickbacks, or other illicit purposes under the guise of legitimate expenses. Criminals typically create fake invoices or modify existing ones to overstate costs, making suspicious outflows appear lawful. In cross-border scenarios, an importer may pay an invoiced price above fair market value, effectively transferring extra funds to the exporter and disguising them as standard trade settlements. In some cases, two sets of invoices are produced—one reflecting the true cost and a second, inflated invoice to justify higher remittances—while the excess is covertly funneled back to conspirators. Government or private procurement processes are also vulnerable, as suppliers can overcharge for goods or services then pass the surplus to complicit officials or beneficiaries. These schemes exploit otherwise legitimate billing practices, making detection more challenging for financial institutions and regulators.

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Code
T0008.002
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Name
Inflated Transaction Pricing
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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
2025-03-12
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Modified
2025-04-02
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Over-Invoicing

Tactics

ML.TA0007
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By overstating costs and issuing inflated invoices, criminals embed illicit funds within seemingly legitimate trade or procurement expenses, obscuring the direct link to their illicit source. This manipulation of invoice pricing functions primarily as a layering tactic, creating complex transaction trails that hinder the detection and tracing of illegal proceeds.

Risks

RS0002
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Product Risk
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Criminals exploit the inherent subjectivity of pricing within trade and invoicing products (e.g., letters of credit, invoice financing) by inflating the stated cost of goods or services. This over-invoicing creates surplus funds that appear legitimate, allowing illicit proceeds to be laundered through routine commercial transactions. This is the primary vulnerability, as it relies on the financial product’s dependence on declared invoice values without thorough verification of market pricing.

Indicators

IND00022
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Repeated issuance of invoices with unit prices or overall costs that exceed established industry or market benchmarks, with no valid documentation to justify the markup.

IND00029
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Invoice line items indicating higher quantities or inflated unit costs compared to corresponding shipping or delivery records.

IND00030
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Frequent last-minute revisions of originally agreed price terms to higher amounts, without any documented business rationale.

IND00031
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Payments regularly exceeding contracted or negotiated amounts, with no evidence of credit notes or refunds to reconcile the overpayment.

IND00032
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Addition of ambiguous 'service fees' or 'facilitation charges' that elevate total invoiced amounts well above prevailing industry benchmarks.

IND00033
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Multiple sets of invoices for the same transaction, each containing conflicting pricing data, with no documented justification for the discrepancies.

IND00609
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Buyer and seller entities found to share beneficial ownership, yet routinely exchanging goods or services at inflated valuations.

Data Sources

  • Offers reliable market benchmarks, historical trends, and real-time pricing indices for various commodities.
  • Enables direct comparisons of invoiced amounts to typical market rates, exposing potential overpricing in trade transactions used to disguise illicit funds.
  • Includes original contracts, invoices, line items, pricing details, and payment terms.
  • Enables detection of inflated prices, hidden fees, duplicate invoicing, or unexplained price changes.

Financial institutions can validate invoice amounts against actual payments, revealing overcharging indicative of inflated transaction pricing.

  • Provide details of actual payment amounts, timestamps, and involved parties.
  • Highlight overpayments beyond contractual terms or frequent high-value transfers.

These records help detect recurring inflated payments with no corresponding refunds, a hallmark of inflated transaction pricing schemes.

  • Covers shipping logs, bills of lading, and customs declarations.
  • Facilitates reconciliation of declared goods, quantities, and valuations against invoiced amounts.

This cross-check helps reveal inflated or otherwise manipulated pricing in cross-border trade scenarios.

  • Contains official registration details, shareholding, and beneficial ownership information.
  • Reveals overlapping ownership structures between buyers and sellers, a key enabler for collusive pricing schemes.

By exposing relationships among transacting parties, investigators can uncover scenarios where inflated invoices serve to move funds between related entities.

Mitigations

Apply heightened scrutiny to customers and suppliers involved in pricier or complex trade relationships. Validate the market reasonableness of invoiced amounts, request itemized cost breakdowns, and require documentation supporting any premium pricing to uncover hidden overcharges or beneficiary kickbacks.

Implement targeted monitoring rules for cross-border or procurement-related payments that exceed typical market values or contractual norms. Compare invoiced amounts to industry benchmarks, flagging and escalating any anomalies that suggest inflated pricing or over-invoicing for immediate investigation.

Provide specialized training for trade finance and compliance teams on detecting inflated billing. Instruct staff on recognizing implausible markups, comparing cost data to verified sources, identifying doctored invoices, and escalating mismatches for detailed review.

Use publicly available trade databases, price indices, and external data to confirm that billed amounts align with normal market rates. Cross-verify invoice claims against shipping documents, customs data, and international trade statistics to reveal hidden overpricing or self-dealing arrangements.

Participate in trade-finance intelligence networks to exchange insights on typical commodity values, emerging misinvoicing schemes, and documented overcharging patterns. Use the shared data to benchmark customer invoices against known pricing norms and promptly investigate outliers.

Scrutinize trade finance documentation, shipping records, and market data to detect pricing irregularities. Investigate invoices that notably exceed average commodity rates or industry benchmarks, and cross-check declared quantities, product types, and shipment details for discrepancies consistent with inflated transaction pricing.

Instruments

  • Criminals embed inflated costs in documentation attached to letters of credit, compelling banks to honor payments exceeding the actual value of goods or services.
  • The overpayment appears legitimate since letters of credit inherently carry banking assurance, enabling criminals to launder excess amounts once the letter is settled.
  • The structured nature of letters of credit helps mask artificially high pricing under formal trade finance procedures.
  • Criminals issue or modify invoices at inflated amounts, creating a higher face value in the accounts receivable. This inflated figure disguises additional illicit funds as legitimate receivables.
  • Once settled by complicit or unwitting payers, the surplus flows back to the criminals under the appearance of standard business transactions.
  • The legitimate form of invoices obscures overpricing, making it difficult for financial institutions to detect manipulation in the billing process.

Service & Products

  • Offenders submit shipping documents reflecting inflated costs through documentary collection procedures.
  • Payments to the exporter exceed true market values, with the surplus laundered as routine trade expenses.
  • Criminals create duplicate or falsified invoices showing inflated costs, merging them into legitimate invoice workflows.
  • Limited verification of invoice authenticity or line-item pricing allows over-invoicing schemes to remain undetected.
  • Inflated pricing in letters of credit documentation compels banks to honor payments exceeding the genuine value of goods.
  • Criminals launder the surplus as legitimate trade proceeds once the letter of credit is settled.
  • Criminals route inflated invoice transactions through standard payment channels, blending them with legitimate business payments.
  • Automated or high-volume payment systems often lack thorough scrutiny, allowing disguised overpayments to pass as routine transactions.
  • Malicious actors inflate invoice values for cross-border shipments, securing inflated payments under various trade finance instruments.
  • The excess funds are labeled as legitimate trade settlements, obscuring the true nature of the transaction.
  • Criminals include overstated valuations in documentation handled by trade facilitators, such as customs forms and shipping logs.
  • These inflated amounts pass as standard trade protocols, concealing illicit gains within typical cross-border movements.
  • Criminals embed inflated prices within purchase orders or invoices, then leverage supply chain financing to receive early payments on these exaggerated values.
  • This effectively laundered difference is cloaked within standard supply chain workflows.
  • Illicit organizations present artificially inflated invoices to factor or discount arrangers.
  • Once financed, the surplus is returned to the criminals, appearing as lawful proceeds from account receivables.

Actors

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.

Illicit operators orchestrate inflated transaction pricing by:

  • Creating false or altered invoices to overstate costs.
  • Coordinating with complicit parties to siphon the surplus as bribes or kickbacks.

These practices make overpayments appear legitimate to financial institutions, hindering effective detection.

Suppliers or distributors participate in inflated transaction pricing by:

  • Overcharging for goods or services in contracting or procurement.
  • Diverting the excess to conspirators as kickbacks or bribes.

These overstated invoices pass through financial systems as normal business expenses, evading scrutiny of unusual payment flows.

Public officials can collude with suppliers to inflate pricing in government procurements by:

  • Approving or directing purchases at inflated rates.
  • Receiving the surplus as bribes or kickbacks through seemingly lawful disbursements.

This arrangement blurs the line between legitimate state spending and illicit diversion, challenging financial oversight.

Organizational officials in private entities exploit inflated transaction pricing by:

  • Authorizing over-invoicing schemes that disguise excess payments as routine operational costs.
  • Retrieving or redistributing the surplus outside official records for personal or collective gain.

These maneuvers undermine accurate financial reporting, impeding financial institutions’ ability to detect misappropriated funds.

References

  1. FATF (Financial Action Task Force). (2012, June). Specific risk factors in the laundering of proceeds of corruption. FATF/OECD. https://www.fatf-gafi.org/en/publications/Methodsandtrends/Specificriskfactorsinthelaunderingofproceedsofcorruption-assistancetoreportinginstitutions.html

  2. McSkimming, S. (2010). Trade-based money laundering: Responding to an emerging threat. Deakin Law Review. https://doi.org/10.21153/dlr2010vol15no1art116

  3. Zeng-an, G., Li-fang, W. (2006).Transfer Price-based Money Laundering in International Trade, International Conference on Management Science and Engineering, Doi: 10.1109/ICMSE.2006.314201. https://ieeexplore.ieee.org/document/4105064

  4. OECD. (2019). Money Laundering and Terrorist Financing Awareness Handbook for Tax Examiners and Tax Auditors. OECD. www.oecd.org/tax/crime/money-laundering-and-terrorist-financing-awareness-handbook-for-tax-examiners-and-tax-auditors.pdf

  5. Pang Kin Keong, Lai Wei Lin, Chia Der Jiun. (2024). National asset recovery strategy 2024 Singapore. Ministry of Home Affairs, Ministry of Finance, Monetary Authority of Singapore (MAS). https://www.mas.gov.sg/publications/monographs-or-information-paper/2024/national-asset-recovery-strategy