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Over-Invoicing, Under-Invoicing and Trade-Based Money Laundering: Testing Import-Export Documents, Customs Valuation and the Actual Goods Trail

Over-invoicing or under-invoicing may indicate a customs valuation dispute, an accounting inconsistency, a commercial pricing difference, a foreign-exchange contravention or, in an appropriate case, an alleged method of transferring value across borders. It does not establish trade-based money laundering merely because the declared price differs from a benchmark. This detailed guide explains how investigators and defence teams should reconstruct the complete transaction through the contract, purchase order, commercial invoice, Bill of Entry, Shipping Bill, Bill of Lading, Letter of Credit,

Premium11 Aug 202624 min readCriminal DefencePMLAED SummonsECIRProvisional Attachment
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Over-Invoicing, Under-Invoicing and Trade-Based Money Laundering: Testing Import-Export Documents, Customs Valuation and the Actual Goods Trail

Over-invoicing or under-invoicing may indicate a customs valuation dispute, an accounting inconsistency, a commercial pricing difference, a foreign-exchange contravention or, in an appropriate case, an alleged method of transferring value across borders. It does not establish trade-based money laundering merely because the declared price differs from a benchmark. This detailed guide explains how investigators and defence teams should reconstruct the complete transaction through the contract, purchase order, commercial invoice, Bill of Entry, Shipping Bill, Bill of Lading, Letter of Credit,

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