What is trade-based money laundering, and what red flags would you train transaction reviewers to spot?

Trade-based money laundering (TBML) moves illicit value through the trade system by misrepresenting trade transactions — disguising the proceeds as legitimate commerce. Core techniques: over- or under-invoicing goods (mispricing to shift value), multiple invoicing for the same shipment, over- or under-shipping (including phantom shipments with no goods), and falsely describing goods to obscure quality or quantity. Red flags reviewers should spot: prices materially out of line with market, goods inconsistent with the customer's business, circuitous routing through high-risk jurisdictions, payments by third parties unrelated to the trade, repeated amendments to letters of credit, and documentation that doesn't reconcile (shipping vs invoice vs payment). TBML is hard to detect because each leg looks routine; the signal is in the inconsistencies across documents and pricing.