Cross-Border Settlement Document Manipulation

Criminals fabricate or alter settlement records to exploit cross-border or regional payment frameworks (e.g., SUCRE) under the appearance of legitimate trade. They often reference fictitious suppliers or inflate invoice values to disguise illegal funds and thwart routine checks. Exploiting multi-jurisdictional gaps, these launderers leverage limited cross-border oversight and the absence of uniform data standards, complicating regulators’ attempts to authenticate documents or trace suspicious flows. By presenting fraudulent paperwork as valid, they circumvent standard due diligence, obscure illicit proceeds, and operate seamlessly across transnational payment channels.

[
Code
T0012.001
]
[
Name
Cross-Border Settlement Document Manipulation
]
[
Version
1.0
]
[
Parent Technique
]
[
Risk
Product Risk, Jurisdictional Risk
]
[
Created
2025-03-12
]
[
Modified
2025-04-02
]

Falsified Documentation in SUCRE System Transfers

Tactics

Falsified cross-border settlement documents obscure the origin of illicit funds behind seemingly legitimate international transactions.

Risks

RS0002
|
Product Risk
|

This technique relies on falsifying trade finance and settlement documents, such as invoices, bills of lading, and letters of credit, exploiting the inherent vulnerability of documentary-based products. Financial institutions and settlement networks depend on the accuracy of these records for cross-border transactions, making them susceptible when criminals alter or forge paperwork to legitimize illicit funds.

RS0004
|
Jurisdictional Risk
|

Criminals exploit uneven regulatory scrutiny and differing data standards across multiple countries participating in regional or cross-border settlement frameworks (e.g., SUCRE). By operating transnationally and forging documentation, they circumvent coordinated oversight, obscure illicit proceeds under purported trade transactions, and take advantage of gaps in cross-border AML enforcement. This is the primary vulnerability targeted by this technique.

Indicators

IND00704
|

Customer resubmits settlement documents for the same transaction multiple times, each version reflecting altered trade values or product details without justification.

IND01949
|

Large payments referencing cross-border settlement documents with conflicting invoice numbers and shipping data.

IND01950
|

Frequent wire transfers tied to multi-jurisdictional settlement frameworks that surpass typical trade volumes without matching shipping confirmations.

IND01954
|

Cross-border transactions leverage specialized settlement systems (e.g., SUCRE) yet involve goods for which neither counterparty has a verifiable import/export record.

IND01957
|

Multiple associated entities use nearly identical shipping references in their cross-border settlement documents, suggesting shared or duplicated paperwork.

IND01964
|

Cross-verification with official customs or shipping data shows no record or drastically different details for shipments claimed in cross-border settlement documents.

Data Sources

  • Includes official import/export entries, shipping manifests, and customs clearances.
  • Supports verification of whether purported cross-border shipments actually occurred, exposing fabricated or inconsistently reported settlement documents.
  • Centralizes risk ratings, AML/CFT compliance statuses, and details about cross-border financial frameworks.
  • Identifies high-risk jurisdictions or specialized payment systems (e.g., SUCRE) often targeted for document manipulation schemes.
  • Provides invoice details, including numbers, dates, values, product descriptions, and counterparties, as well as contractual clauses.
  • Allows for the verification of inconsistencies in repeated or revised settlement documents, uncovering fabricated trade values or items.
  • Records all wire transfers and associated metadata, including timestamps, amounts, sender/receiver details, and reference fields.
  • Enables the comparison of declared trade values in cross-border settlement documents with actual transaction amounts, helping to detect inflated or fabricated payments.
  • Aggregates data on businesses and individuals, including registration details, affiliations, and beneficial ownership.
  • Helps uncover collusion or coordinated schemes among multiple entities submitting nearly identical cross-border settlement documents.
  • Maintains version histories, timestamps, and user access logs for submitted settlement documents.
  • Reveals repeated or suspicious alterations in cross-border documentation, aiding in the detection of manipulated invoices or trade references.
  • Provides specialized tools and forensic checks to identify tampering, forgery, or digital manipulation in key documents.
  • Enhances the validation of cross-border settlement paperwork by flagging signs of fabricated or altered records, strengthening fraud detection beyond standard trade data reviews.
  • Encompasses official shipping logs, bills of lading, and other trade certificates.
  • Compares declared product or shipment details in cross-border settlement documents with actual shipping data, exposing fraudulent or fabricated records.
  • Details cross-border payments, including amounts, countries, bank intermediaries, and settlement references.
  • Facilitates the detection of mismatches between declared shipping/invoice data and actual cross-border funds movement, flagging manipulated settlement documents.

Mitigations

Apply more rigorous checks on high-risk cross-border transactions by referencing specialized regional frameworks (e.g., SUCRE). Confirm the existence of the listed suppliers, verify shipping routes using independent sources, and compare declared invoice values to known market rates. Thoroughly evaluate the legitimacy of each document to prevent criminals from concealing illegal proceeds behind altered or fabricated cross-border settlement records.

Implement targeted monitoring scenarios specifically focused on cross-border settlement channels, including SUCRE or similar frameworks. Flag transactions with re-submitted or inconsistent settlement documents, inflated invoice amounts, or contradictory shipping references. Correlate transaction flows with typical trade volumes and shipping routes to expose fraudulent paperwork used to disguise illicit funds under the guise of legitimate cross-border trade.

Leverage shipping registries, online trade databases, and other publicly accessible datasets to validate alleged suppliers, shipping routes, and trade values listed in cross-border settlement documents. Check for mismatches between claimed shipment details and independently verifiable records to uncover fabricated or inflated invoices. This measure counters the use of fictitious data by criminals seeking to legitimize illicit flows.

Establish structured intelligence-sharing arrangements with other institutions, regulators, and relevant authorities to exchange real-time red flags and typologies related to fraudulent cross-border settlement documents. By sharing indicators of document manipulation, repeated invoice inflation, or suspicious supplier data, institutions can strengthen collective detection and disrupt criminal schemes that exploit multi-jurisdictional gaps.

Conduct detailed reviews of cross-border settlement documents, shipping information, and invoice details related to transactions spanning multiple jurisdictions. Match reported trade values and product descriptions against actual shipping records and customs filings to detect inconsistencies. By scrutinizing these documents for inflated values or fictitious suppliers, institutions can identify schemes where forged paperwork is used to launder funds across borders.

Instruments

Criminals submit falsified shipping documents, such as forged bills of lading or altered product details, to meet the documentary requirements under letters of credit. This action triggers disbursements for supposed exports or imports that do not correspond to actual goods or services, effectively laundering illicit funds. The reliance on paper or electronic documentation, rather than in-person inspections, complicates the ability of financial institutions to detect discrepancies across multiple jurisdictions.

Forged or altered trade finance documentation—such as shipping manifests, bills of lading, or inspection certificates—allows criminals to simulate legitimate cross-border transactions. By inflating the declared value or misrepresenting shipment details, they secure or move funds through official channels while obscuring the true illicit origin. The complexity of verifying trade-related paperwork across multiple regulatory regimes facilitates the concealment of suspicious transactions.

By fabricating or inflating invoices for non-existent or overvalued cross-border transactions, criminals generate false accounts receivable to justify large proceeds moving through international payment channels. Banks and regulators see these documents as legitimate claims for goods or services, allowing illicit funds to flow under the guise of trade settlements. The multi-jurisdictional context and lack of uniform data-sharing standards hinder thorough verification of invoice authenticity, enabling further layering of illicit proceeds.

Service & Products

  • Falsified bills of lading and other shipment documents allow criminals to claim payment for goods that do not exist or are overstated in value.
  • The reliance on documentary checks rather than physical inspections fosters opportunities to disguise illicit proceeds as legitimate trade settlements.
  • Criminals submit altered or forged settlement documents to banks, triggering letters of credit for transactions with artificial or non-existent trades.
  • The bank’s reliance on paper or electronic forms of documentation rather than physical verification creates a loophole for disguising illicit proceeds.
  • Fraudulent shipping manifests, invoices, and related paperwork are fabricated or altered to justify inflated or fictitious cross-border transactions.
  • These documents are then submitted to financial institutions or authorities, appearing valid and bypassing routine checks.
  • Criminals leverage forged settlement documents to obtain financing for purported international trade, concealing the actual movement of illicit funds.
  • Inflated or fictitious invoices enable launderers to extract funds from trade finance instruments while obscuring real financial flows.
  • Criminals present falsified settlement documents in cross-border payment channels, masking illicit funds as proceeds from legitimate trade.
  • They exploit varying regulatory standards across jurisdictions, making it difficult to detect mismatched or inflated invoices in real time.

Actors

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.

Document forgers knowingly create or alter cross-border settlement records to:

  • Equip criminals with seemingly authentic trade documentation supporting fraudulent cross-border transactions.
  • Fabricate or manipulate invoice data, shipping manifests, or other settlement details to disguise illicit funds.

This role undermines financial institutions’ due diligence processes by concealing the true nature of financial flows behind falsified paperwork.

Financial institutions, including correspondent banks and trade finance providers, are exploited when criminals:

  • Submit falsified settlement documents to access cross-border payment networks or secure trade finance.
  • Exploit inconsistent data standards and multi-jurisdictional loopholes to evade detection.

Their reliance on documentary checks and routine processing can mask suspicious transactions, complicating efforts to trace illicit flows.

References

  1. MAS (Monetary Authority of Singapore). (2024). Money laundering risk assessment report Singapore 2024. MAS. https://www.mas.gov.sg/publications/monographs-or-information-paper/2024/money-laundering-national-risk-assessment