Transnational Trade-Based Money Laundering ("TBML") constitutes one of the most challenging and malevolent forms of money laundering to investigate. According to Immigration and Customs Enforcement ("ICE"), "Criminal organizations frequently exploit global trade systems to move value around the world by employing complex and sometimes confusing documentation associated with legitimate trade transactions." The flagrant volume of the criminal activity has resulted in ICE establishing the Trade Transparency Unit, designed to target transnational trade-based money laundering worldwide. This shouldn't surprise you, since criminals are now seeking novel and creative means to effectuate money laundering and subsequently escape detection. Your financial institution's BSA/AML program will be strengthened and benefit tremendously if you undertake efforts to educate employees on key elements of TBML to pay attention to in their daily money laundering investigations. Reputational risk at your financial institution will also remain minimized with a focus on extinguishing egregious and often disregarded methods of money laundering, as these criminals will ultimately be coerced into locating other outlets to perpetuate their illicit behaviors.