Trade-based money laundering (TBML) empowers criminals to run free post-Brexit

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Purpose – This paper provides unique empirical findings exploring the impact of the UK’s post-Brexit Economic Strategy to boost trade with developing countries on the UK banking sector’s ability to manage trade-based money laundering risks.

Design/methodology/approach - Exploratory research design that utilised structured literature review, followed by semi-structured interviews with key subject matter experts employed by large UK banks.

Findings – Both banks and law enforcement struggle to prioritise TBML intelligence discovery due to deficient skills, resources, technology, and lack of strong regulatory stimulus. The regulated sector calls for the UK Anti-Money Laundering (AML) reform that would better incentivise TBML deterrence, yet the Government underestimates the money laundering risks while trading with high-risk jurisdictions post-Brexit.

Research limitations/implications - The findings are based on a small sample of six semi-structured interviews with difficult to access population of key subject matter experts. Despite the small sample, participants provided well-articulated and informed insights.

Practical implications - The UK’s post-Brexit Economic Strategy to boost trade with developing countries downplays the TBML risks it carries. The findings should alert UK banks, law enforcement, and the Government who will collectively bear the responsibility to effectively manage TBML while enabling smooth trading.

Originality/value - The research provides unique perceptions of UK banks’ senior subject matter experts on managing TBML threats from opportunistic criminals.
Original languageEnglish
JournalJournal of Money Laundering Control
Early online date15 Jul 2021
Publication statusEarly online - 15 Jul 2021


  • Brexit
  • Compliance
  • Organized crime
  • Trade-based money laundering
  • TBML
  • AML


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