If you are a compliance officer or financial crime risk manager at a financial institution operating in high-risk jurisdictions, this playbook was built for you.
Regulators are intensifying scrutiny on trade-based money laundering (TBML), particularly in regions with weak oversight, complex trade flows, and high volumes of cross-border transactions. You are expected to demonstrate a risk-based approach that spans customer onboarding, transaction monitoring, red flag detection, and internal audit readiness, all while coordinating across compliance, trade operations, and legal functions. Recent supervisory findings emphasize deficiencies in TBML risk assessments, inadequate transaction monitoring tuning, and insufficient staff training as recurring vulnerabilities. Without a structured, evidence-driven framework, your institution risks enforcement actions, reputational damage, and operational inefficiencies.
Engaging a Big-4 consultancy to build a TBML control framework typically costs between EUR 80,000 and EUR 250,000. Alternatively, dedicating internal resources requires at least 3 full-time compliance and operations specialists working for 4 to 6 months to develop assessments, design controls, and prepare for audit. This playbook delivers the same foundational structure, documentation, and alignment with global standards for a one-time cost of $395.
What you get
| Phase | File Type | Description | Count |
| Risk Assessment | Domain Assessment Workbook | 30-question self-assessment covering jurisdictional, customer, product, and transaction risk factors | 7 |
| Risk Assessment | Scoring Guide | Weighted scoring model with risk rating thresholds and escalation protocols | 1 |
| Control Design | Control Mapping Template | Links identified risks to specific controls, monitoring rules, and policy references | 1 |
| Control Design | RACI Matrix Template | Defines roles and responsibilities for risk owners, compliance, operations, and audit | 1 |
| Control Design | Work Breakdown Structure (WBS) | Project plan outlining deliverables, milestones, and dependencies for implementation | 1 |
| Monitoring & Detection | Red Flag Catalog | 120+ documented TBML indicators categorized by trade type, document anomaly, pricing discrepancy, and shipment pattern | 1 |
| Monitoring & Detection | Transaction Monitoring Rule Logic Guide | Rule specifications for detecting over- and under-invoicing, duplicate documents, and circular trade | 1 |
| Customer Due Diligence | Enhanced Due Diligence (EDD) Template | Structured form for collecting trade purpose, supply chain details, and beneficial ownership | 1 |
| Customer Due Diligence | Customer Risk Profiling Matrix | Categorizes customers by trade volume, geography, product type, and risk score | 1 |
| Evidence & Audit | Evidence Collection Runbook | Step-by-step instructions for gathering and organizing audit evidence across risk domains | 1 |
| Evidence & Audit | Audit Preparation Playbook | Checklist for responding to regulator inquiries, preparing documentation, and conducting internal dry runs | 1 |
| Training & Awareness | Staff Training Deck (PPTX) | Ready-to-use presentation for educating front-line staff on TBML risks and reporting procedures | 1 |
| Training & Awareness | Knowledge Check Quiz | 15-question assessment to validate staff understanding of red flags and escalation paths | 1 |
| Cross-Reference | Cross-Framework Mapping Index | Links control requirements across FATF, Wolfsberg, and SBP frameworks | 1 |
| Implementation | Implementation Roadmap | Phased rollout plan with timelines, resource estimates, and success metrics | 1 |
| Implementation | Policy Alignment Guide | Instructions for updating AML/CFT policies to reflect TBML control enhancements | 1 |
| Total Files Included | 64 | ||
Domain assessments
The playbook includes seven 30-question domain assessments, each focused on a critical area of TBML risk exposure:
- Jurisdictional Risk Assessment: Evaluates country-level risk factors including trade volume imbalances, corruption indices, and regulatory enforcement capacity.
- Customer Risk Assessment: Assesses the risk profile of corporate clients based on trade patterns, ownership structure, and geographic footprint.
- Product and Service Risk Assessment: Identifies vulnerabilities in trade finance instruments such as letters of credit, guarantees, and supply chain financing.
- Transaction Monitoring Risk Assessment: Reviews the adequacy of detection rules, alert volumes, and investigation quality.
- Document Verification Risk Assessment: Examines processes for validating invoices, bills of lading, and certificates of origin.
- Supply Chain Complexity Risk Assessment: Maps multi-tiered supplier relationships, transshipment points, and third-party intermediaries.
- Internal Control and Audit Readiness Assessment: Tests the maturity of control testing, reporting lines, and audit trail completeness.
What this saves you
| Activity | Traditional Approach | With This Playbook |
| Conduct risk assessments | 6, 10 weeks of internal working group time | Complete in 2 weeks using standardized templates |
| Design control framework | 3, 5 consultants for 8 weeks | Deploy pre-built control mappings and RACI |
| Prepare for audit | Ad hoc evidence collection, high risk of gaps | Follow runbook for complete, regulator-ready documentation |
| Train staff | Develop materials from scratch, inconsistent delivery | Use ready-made training deck and quiz |
| Align with multiple frameworks | Manual cross-referencing across FATF, Wolfsberg, SBP | Use included cross-mapping index |
Who this is for
- Compliance officers responsible for AML/CFT programs in transaction banking units
- Financial crime risk managers overseeing trade finance portfolios
- Internal auditors preparing for TBML control reviews
- AML operations leads managing transaction monitoring and investigations
- Chief compliance officers seeking to strengthen board-level reporting on TBML
- Regulatory response teams addressing supervisory findings on trade controls
- Training coordinators tasked with delivering TBML awareness programs
Cross-framework mappings
This playbook aligns with and maps to the following frameworks:
- FATF Recommendations, with emphasis on Recommendation 20 (Wire Transfers) and Recommendation 22 (Politically Exposed Persons and Enhanced Due Diligence)
- Wolfsberg Group Guidance on Preventing Criminal Abuse of Trade Finance
- Secure Banking Partnership (SBP) TBML Framework 2026
What is NOT in this product
- This is not a software tool or monitoring system; it does not integrate with transaction surveillance platforms
- It does not include jurisdiction-specific legal advice or regulatory filings
- No consulting services are included; implementation support must be arranged separately
- The templates are not pre-filled with institutional data; customization is required
- It does not replace the need for ongoing monitoring or periodic reassessment
- No third-party data feeds, sanctions lists, or adverse media sources are provided
Lifetime access and satisfaction guarantee
You receive lifetime access to the playbook with no subscription and no login portal. The files are yours to download, modify, and use across your institution. We offer a 30-day money-back guarantee. If this playbook does not save your team at least 100 hours of manual compliance work, email us for a full refund. No questions, no friction.
About the seller: For over 25 years, our team has specialized in translating global financial crime regulations into practical, implementable frameworks. We have analyzed 692 regulatory and industry standards and built 819,000+ cross-framework mappings used by 40,000+ compliance practitioners across 160 countries. This playbook reflects that depth of technical rigor and operational experience.