Definition
Trade-based money laundering (TBML) disguises illicit proceeds through trade transactions—often mispriced goods, phantom shipments, or payment flows that do not match underlying commerce. Card-based TBML patterns can involve suspicious charges and structured repayments routed through payment networks.
Key Points
- 2026-10-08: U.S. regulators cited ~$13B in suspected TBML-related card activity at american-express National Bank over roughly a decade—monitoring and SAR failures, not criminal findings against the bank in public orders (2026-10-08-occ-amex-350m-aml-enforcement)
Regulatory orders describe suspected activity volumes; distinguish from proven laundering in reporting.