GIABA flags trade-based money laundering as rising threat
Trade-based money laundering (TBML) is emerging as a major front in West Africa’s fight against illicit finance, with regulators warning that criminal networks are using trade and banking channels to move vast sums across borders without detection. At the 2025 FATF/GIABA Joint Experts Meeting in Accra, the Inter-Governmental Action Group against Money Laundering in West Africa (GIABA) underscored that trade-based financial crimes are among the most complex and least understood threats confronting the region.
GIABA’s Director-General, Edwin W. Harris Jr., told participants that no country in the region can credibly claim victory over money laundering or terrorist financing. He noted that progress is ongoing, and the Accra forum forms part of a broader, collective push to strengthen defenses and share insights across jurisdictions.
The meeting convened anti-money laundering (AML) and counter-terrorist financing (CFT) specialists from across the Financial Action Task Force (FATF) global network to examine new typologies, with TBML topping the agenda. Delegates focused on how criminal groups exploit cross-border trade systems, digital payment platforms, and corporate fronts to obscure illicit proceeds—actions that undermine tax collection, distort markets, and erode public confidence in financial systems.
Harris emphasized that GIABA’s regional project on trade-based financial crime is designed to deliver practical tools, including risk indicators and case studies, to help banks, Customs agencies, and regulators more effectively detect suspicious trade flows. He stressed the need for an agile, evidence-based, and regionally coherent response.
Evidence points to the scale of the challenge. Between April 2020 and August 2025, commercial banks in Ghana reportedly processed about US$20 billion in foreign transfers that were not matched with corresponding imports. These transactions—amounting to roughly GH¢31 billion—were executed through import declaration forms that failed to meet documentation standards set by the central bank.
Analysts have flagged patterns where multiple transfers were processed for the same clients despite obvious red flags, suggesting shortcomings in compliance oversight. Less than two percent of transfers over the five-year period were matched with actual imports, contributing to an estimated GH¢22.6 billion in forgone government revenue from unpaid duties and taxes.
Albert Kojo Twum Boafo, Chief Executive Officer of Ghana’s Financial Intelligence Centre (FIC), described the trend as deeply concerning and said that the country is enhancing both legal and operational frameworks ahead of GIABA’s third-round mutual evaluation. He noted that criminals are leveraging increasingly sophisticated tools—including artificial intelligence—and stressed the imperative for authorities to stay ahead of rapidly evolving tactics.
Boafo added that the FIC collaborates closely with banks to flag suspicious trade transactions but called for faster, real-time cooperation. He explained that more immediate alerts would enable authorities to intervene before illicit funds are dispersed beyond reach.
The Accra meeting also reflected on recent regional gains. Burkina Faso and Nigeria were removed from FATF’s “grey list” of jurisdictions under increased monitoring, a development that signals improvements in national AML/CFT regimes. Still, Harris cautioned that vigilance is essential, as illicit trade networks continue to adapt quickly to regulatory and enforcement measures.
Participants agreed that strengthening detection and enforcement will require a multi-pronged approach: tightening documentation and verification around trade transactions; enhancing data analytics and information-sharing between banks, Customs, and FIUs; improving beneficial ownership transparency to pierce corporate fronts; and investing in capacity building for frontline officers. Financial institutions, in particular, were urged to sharpen transaction monitoring rules to capture anomalies such as repeated transfers for single clients without corresponding goods movement, over- and under-invoicing patterns, circular trade flows, and discrepancies between shipping records and financial messages.
Beyond the technical measures, experts stressed the importance of coordinated policy reforms and cross-border cooperation. Regional alignment on red-flag indicators, standardized reporting protocols, and joint investigations can help close gaps that criminals exploit when moving funds between jurisdictions. Public-private partnerships were highlighted as essential, given that banks and logistics providers are often the first to spot irregularities in payment flows and documentation.
The overarching message from the forum was clear: TBML is accelerating in sophistication and scale, demanding responses that are faster, smarter, and more collaborative. While recent progress in some countries demonstrates growing maturity in West Africa’s AML/CFT architecture, stakeholders agreed that sustained vigilance—and continuous adaptation—will determine the region’s success in disrupting trade-based illicit finance.
