Of 43 million suspicious activity reports filed by banks in 2023, exactly 0.01% resulted in criminal convictions—exposing a compliance system that functions more as security theatre than genuine crime prevention.
Speaking at the 2025 BAFT Global Annual Meeting an industry panel examined red flags in trade and supply chain finance. Leading experts revealed how traditional TBML detection methods are crumbling against increasingly sophisticated money laundering networks. The discussion, moderated by CGI’s Patrick Deilbus, exposed critical gaps between regulatory compliance requirements and enforcement outcomes, with alarming implications for global trade security.
The TBML Detection Crisis
The statistics reveal a fundamental breakdown in trade-based money laundering prevention. As TradeSun CEO Nigel Hook told the BAFT audience: “Only 4% got any attention from federal law enforcement and only 0.3% led to any arrests and 0% 0.1% led to any convictions.” This represents a spectacular failure rate that essentially gives criminal networks free rein to manipulate trade flows.
Hook’s perspective carries particular authority given his role as director of the FBI’s Citizens Academy and experience combating cross-border crimes through San Diego’s initiatives—the world’s largest border crossing with over 40 million annual crossings. “When you see the impact of human trafficking, that’s what’s driving the red flags,” he observed, connecting TBML detection failures to broader organised crime networks that rely on trade finance manipulation.
TBML Networks Exploit System Vulnerabilities
The enforcement vacuum creates dangerous asymmetries in trade-based money laundering detection. While banks navigate lengthy regulatory approval processes for new technologies, criminal organisations deploy the same tools immediately for document forgery and invoice manipulation. “The organized crime folks don’t have those restrictions and they probably have bigger budgets frankly,” Hook warned.
This speed differential proves critical as global trade shifts toward open account transactions—now representing 80% of the market—where TBML schemes flourish beyond traditional documentary credit controls. Criminal networks systematically exploit these regulatory blind spots, using techniques like phantom shipments, multiple invoicing, and tariff evasion to obscure illicit fund flows.
Hook’s insights from combating human trafficking networks reveal the broader stakes: “If you can stop the flow of goods, the flow of money, essentially it’s a shot through the heart to these organized crimes.” The failure to detect TBML effectively enables predicate crimes ranging from drug trafficking to forced labour, making trade finance a critical battlefield in organised crime prevention.