Abnormal source or destination countries for a product that do not make economic sense (e.g. commodities that are not widely grown in or exported from a source country, imports to a destination country that is a large producer and exporter of that commodity).
Shipments or transactions where descriptions of ports are vague (e.g. 'Any safe world port').
Trade in products which are difficult to value.
Shipment in commodities which seem inconsistent with a client’s business profile.
Change of the delivery address at any time after a commodity was shipped, as this could signal an intention to divert a shipment.
Discrepancies between the description or value of a commodity in shipping documents and invoices, relative to the actual goods shipped or actual value in payments made.
Questionable paperwork such as duplicate certificate numbers; missing permit details; potentially falsified signatures; anomalous, incomplete, or suspicious certificates of origin; dubious or vague descriptions of commodities on shipping documents and invoices and details such as the ship's name; IMO number, port of loading, and port of discharge missing or incomplete in the shipping documents.
Transactions which involve the use of repeatedly amended or frequently extended letters of credit without reasonable justification or for reasons like ‘changes of beneficiary or location of payment’.
Trade in noncertified timber (the two most widely used certification schemes are the Forest Stewardship Council (FSC) and the Programme for the Endorsement of Forest Certification (PEFC)).
Trade in any timber species that appears on the CITES Appendix I or II.
Suppliers who aren’t transparent about the origins of any commodities or where the supply chain is overly long or complex (or where it involves companies with post office boxes rather than physical addresses): it is important to understand what a ‘normal’ supply chain looks like for any relevant commodities (e.g. paper tends to have shorter supply chains (e.g. forest, pulp mill and printer) than plywood, which goes through multiple brokers and supply tiers, and therefore warrants greater due diligence).
Significant differences between the wire transfers received and the noted freight on board value exported.
Consignments split or spread across multiple shipments.
The use of free trade zones and free ports.
Shipments that do not make economic sense (e.g. the use of a forty-foot container to transport a small amount of relatively low value merchandise).
Indications of carousel transactions (the repeated importation and exportation of the same high-value commodity).
Are the owners or senior managers acting as nominee directors to conceal the true beneficial owners? Do the nominee directors appear to have the relevant experience to manage the company?
Transactions where a shipper or a consignee insists on paying transportation costs in cash, or where these are paid by a third party (e.g. not a shipper or a receiver).
Unusual changes of shipping routes (e.g. overly circuitous routes) or where a commodity is trans-shipped through one or more jurisdictions for no apparent economic or logistical reason.
Where certain documentation in a transaction is numbered sequentially/continuous numbers, which might indicate that either the documentation or the transaction itself is manufactured or false.
An entity that is registered in or has an office in a jurisdiction with weak AML and/or CFT compliance (e.g. on the FATF Black List or Grey List).
The type of commodity being traded appears inconsistent with the exporter or importer’s usual business activities (e.g. a steel company that starts dealing in paper products, or an information technology company that suddenly starts dealing in bulk pharmaceuticals), or with the scale of the exporter or importer’s regular business activities.
The Environmental Crimes Financial Toolkit is developed by WWF and Themis, with support from the Climate Solutions Partnership (CSP). The CSP is a philanthropic collaboration between HSBC, WRI and WWF, with a global network of local partners, aiming at scaling up innovative nature-based solutions, and supporting the transition of the energy sector to renewables in Asia, by combining our resources, knowledge, and insight.