AML Judgment Gap Report · Full findings
Trade and Commodity Finance
This is a specimen. The cases, the weights, the methods and the sources are real, and are what your team would sit and what your own report would cite. The scores are invented, for a hypothetical cohort of 14 people. A real report carries your own results and nothing else.
Your team detects 8 of the 18 money laundering methods that apply to this sector. 7 need action, and 1 of those are rarely covered by standard training.
7 of these are urgent. Your team was tested on them and missed them.
Your assessment is 11 cases, not one. Each covers a different part of your exposure, and the appendix shows how many of your 18 methods each one carries. Measured against the methods that apply to this sector, not against other firms.
Since the last sitting
September cohort against March cohort. Your team detected 3 methods then and 8 now. 3 went backwards.
What to do
For each one, ask a single question. Does the team not know the method, or do they know it and have no rule that would surface it? The first needs a briefing. The second is a control gap, and it is the more serious answer.
- High
- Tested and missed, on a case covering a large part of your exposure.
- Medium
- Tested and missed on a smaller case, or never tested on one that matters.
- Low
- Never tested, and a small part of your exposure.
Ordered by priority. The reason for each is printed with it, so you can disagree with the ranking.
- 01
Capital-Flight Invoicing with Genuine Goods
HighYour team was tested on this and missed it. It sits in The Goods Chain, which covers 7 of the 18 methods that apply to you.
- Result
- Caught 45% of the laundering customer's alerts.
- Tested by
- The Goods Chain — covers 7 of your 18 methods
Now · BriefSend the team the register entry. It has the mechanism, the signal and the sources.
30 days · ControlWhich rule, report or alert would surface this?
Offshore receipt accounts holding balances well above production cost, cover purchases of high-value goods with no commercial logic, and settlement rates away from market.
90 days · Re-testSit The Goods Chain again, on the version the team has not seen.
OwnerTarget date - 02
Counterfeit Goods and IP Crime Proceeds
HighYour team was tested on this and missed it. It sits in The Goods Chain, which covers 7 of the 18 methods that apply to you.
- Result
- Caught 45% of the laundering customer's alerts.
- Tested by
- The Goods Chain — covers 7 of your 18 methods
Now · BriefSend the team the register entry. It has the mechanism, the signal and the sources.
30 days · ControlWhich rule, report or alert would surface this?
Merchant accounts with high chargeback and dispute rates against a narrow product range, settlement to beneficiaries unrelated to the listed merchant, and rapid rotation of storefronts under the same banking relationship.
90 days · Re-testSit The Goods Chain again, on the version the team has not seen.
OwnerTarget date - 03
Dual-Use Goods Diversion
HighYour team was tested on this and missed it. It sits in The Goods Chain, which covers 7 of the 18 methods that apply to you.
- Result
- Caught 45% of the laundering customer's alerts.
- Tested by
- The Goods Chain — covers 7 of your 18 methods
Now · BriefSend the team the register entry. It has the mechanism, the signal and the sources.
30 days · ControlWhich rule, report or alert would surface this?
Sudden growth in trade finance for electronics and machinery through transhipment jurisdictions, buyers incorporated after the export controls took effect, and end-user statements inconsistent with the buyer's business.
90 days · Re-testSit The Goods Chain again, on the version the team has not seen.
OwnerTarget date - 04
High-Value Portable Goods
HighYour team was tested on this and missed it. It sits in The Goods Chain, which covers 7 of the 18 methods that apply to you.
- Result
- Caught 45% of the laundering customer's alerts.
- Tested by
- The Goods Chain — covers 7 of your 18 methods
Now · BriefSend the team the register entry. It has the mechanism, the signal and the sources.
30 days · ControlWhich rule, report or alert would surface this?
Dealer accounts taking third-party payments for goods delivered to someone else, part-exchange chains that never settle in cash, and customers whose purchases exceed any evidenced income.
90 days · Re-testSit The Goods Chain again, on the version the team has not seen.
OwnerTarget date - 05
Illicit Excise Goods and Diversion
HighYour team was tested on this and missed it. It sits in The Goods Chain, which covers 7 of the 18 methods that apply to you.
- Result
- Caught 45% of the laundering customer's alerts.
- Tested by
- The Goods Chain — covers 7 of your 18 methods
Now · BriefSend the team the register entry. It has the mechanism, the signal and the sources.
30 days · ControlWhich rule, report or alert would surface this?
Wholesale accounts with purchase volumes inconsistent with declared duty, rapid movement of goods between connected traders, and cash takings at retail exceeding what the site can support.
90 days · Re-testSit The Goods Chain again, on the version the team has not seen.
OwnerTarget date - 06
Mirror Transfers and Daigou Purchasing
HighYour team was tested on this and missed it. It sits in The Goods Chain, which covers 7 of the 18 methods that apply to you. Training rarely covers this, so a refresher will not fix it.
- Result
- Caught 45% of the laundering customer's alerts.
- Tested by
- The Goods Chain — covers 7 of your 18 methods
- Training
- Rarely covered by standard annual refreshers
Now · BriefSend the team the register entry. It has the mechanism, the signal and the sources.
30 days · ControlWhich rule, report or alert would surface this?
Card accounts repaid in cash or by unrelated third parties, purchase volumes far exceeding personal use, and paired domestic flows in two jurisdictions with no instrument connecting them.
90 days · Re-testSit The Goods Chain again, on the version the team has not seen.
OwnerTarget date - 07
MTIC and VAT Carousel Fraud
HighYour team was tested on this and missed it. It sits in The Goods Chain, which covers 7 of the 18 methods that apply to you.
- Result
- Caught 45% of the laundering customer's alerts.
- Tested by
- The Goods Chain — covers 7 of your 18 methods
Now · BriefSend the team the register entry. It has the mechanism, the signal and the sources.
30 days · ControlWhich rule, report or alert would surface this?
Rapid high-value trading between newly incorporated counterparties in the same goods, payments that pass through in hours, margins too thin to support the businesses, and directors with no trading history in the sector.
90 days · Re-testSit The Goods Chain again, on the version the team has not seen.
OwnerTarget date
On your own report
Each line carries your team’s result, an owner and a date. The re-test at 90 days shows what has moved.
Appendix
Evidence
Everything the finding above rests on, for anyone who wants to check it.
By case
The 11 cases that make up your assessment. Detection rate is the share of the laundering customer’s alerts the team caught. The last column counts people who escalated everything, which catches the laundering customer without deciding anything and scores badly for that reason.
| Case | Your methods | Share of assessment | Runs | Median mark | Detection rate | Escalated everything |
|---|---|---|---|---|---|---|
| The Goods Chain | 7 | 30% | 14 | 49 | 45% | 3 of 14 |
| The Trade Corridor | 4 | 17% | 14 | 87 | 84% | 3 of 14 |
| The Policy Book | 3 | 13% | 14 | 87 | 83% | 3 of 14 |
| The Invoice Pack | 2 | 8% | 14 | 37 | — | — |
| The Relationship Review | 2 | 8% | 14 | 50 | 46% | 2 of 14 |
| The Collection Network | 1 | 4% | 14 | 61 | 57% | 2 of 14 |
| The Merchant Book | 1 | 4% | 14 | 59 | 57% | 4 of 14 |
| The Onboarding Interview | 1 | 4% | 14 | 87 | — | — |
| The Securities Book | 1 | 4% | 14 | 53 | 50% | 3 of 14 |
| The Sponsorship File | 1 | 4% | 14 | 42 | 39% | 3 of 14 |
| The Verification Desk | 1 | 4% | 14 | 85 | 83% | 2 of 14 |
Every method
All 18 methods that apply to this sector, and where each one is documented. Full citations are at amlbenchmark.com/coverage.
| Method | Case | Rate | Result |
|---|---|---|---|
| Mirror Transfers and Daigou Purchasingrarely trainedFinCEN advisory on Chinese Money Laundering Networks (28 August 2025), identifying mirror transactions, money mules and… | The Goods Chain | 45% | Missed |
| Capital-Flight Invoicing with Genuine GoodsGlobal Financial Integrity research on trade misinvoicing | The Goods Chain | 45% | Missed |
| Counterfeit Goods and IP Crime ProceedsEUIPO and OECD, Mapping Global Trade in Fakes 2025 | The Goods Chain | 45% | Missed |
| Dual-Use Goods DiversionUnited States v Mazulina: on 24 June 2026 a federal court in Brooklyn sentenced the former western regional manager of freight… | The Goods Chain | 45% | Missed |
| High-Value Portable GoodsHM Treasury and Home Office, National Risk Assessment of Money Laundering and Terrorist Financing 2025 (July 2025), paragraphs… | The Goods Chain | 45% | Missed |
| Illicit Excise Goods and DiversionHMRC alcohol strategy and enforcement against inward diversion fraud | The Goods Chain | 45% | Missed |
| MTIC and VAT Carousel FraudEuropean Public Prosecutor's Office, 5 May 2026: a businessman was arrested in Italy for laundering and reinvesting the proceeds… | The Goods Chain | 45% | Missed |
| Bulk Cash Smuggling and Cash CouriersNCA press release of 28 May 2026 on a cross-border investigation across the island of Ireland: six arrests in Cookstown and the… | The Collection Network | 57% | Partial |
| Related-Party Circularity in ReceivablesFATF and Egmont Group, Trade-Based Money Laundering: Trends and Developments (December 2020), covering the use of related parties… | The Invoice Pack | — | Partial |
| Services Invoicing with No DeliverableFATF and Egmont Group, Trade-Based Money Laundering: Trends and Developments (December 2020), and the companion FATF Trade-Based… | The Invoice Pack | — | Partial |
| AI-Fabricated Corporate Presencerarely trainedDue diligence industry reporting on generative AI lowering the cost of fabricating a corporate identity — website, product… | The Verification Desk | 83% | Detected |
| Environmental Crime Proceedsrarely trainedUS Treasury (OFAC) press release of 25 June 2026 designating Gasabo Gold Refinery LTD of Kigali, its chairman and general… | The Trade Corridor | 84% | Detected |
| Gold, Refining and Free-Trade Zonesrarely trainedUS Treasury (OFAC) press release of 25 June 2026 designating Gasabo Gold Refinery LTD of Kigali, its chairman Jean Malic Kalima… | The Trade Corridor | 84% | Detected |
| Shadow Fleet and Maritime Sanctions Evasionrarely trainedThe G7 price cap on Russian crude, in force since December 2022 | The Trade Corridor | 84% | Detected |
| Warehouse Receipts and Negotiable Bills of Ladingrarely trainedFATF, Money Laundering Vulnerabilities of Free Trade Zones (March 2010), identifying inadequate AML/CFT safeguards and relaxed… | The Trade Corridor | 84% | Detected |
| Beneficial Ownership ObfuscationThe two largest beneficial ownership regimes moved in opposite directions within a year, and a structure is now easier to hide in… | The Policy Book | 83% | Detected |
| Bribery Conduits and Consultancy PaymentsOperation Lava Jato: in December 2016 Odebrecht and Braskem admitted paying approximately US$788m in bribes to officials across a… | The Policy Book | 83% | Detected |
| Sanctions-Evasion Ownership RestructuringOFSI and FCDO joint guidance on the meaning of ownership and control under UK sanctions, issued following Mints v National Bank… | The Policy Book | 83% | Detected |
How this was measured
Each case is built around one customer who is laundering money. The rate is the share of that customer’s alerts the team caught.
- Detected
- Four fifths of them or more.
- Partial
- Between a half and four fifths.
- Missed
- Half or fewer.
- Untested
- No one has sat a case covering it.
Nothing is reported as detected on the strength of a good overall mark. Findings are suppressed below 3 runs on a case, because a smaller number describes one analyst rather than a team. Methods are declared on the case, not the individual alert, so this reports whether the team detected the method a case is built around rather than scoring each method separately.