The menace of trade-based money laundering (TBML) is an increasing, yet often under-reported, financial and reputational risk to banks and a growing concern to governments and regulators. Transnational crime is worth up to $2.2trn each year and much of it is facilitated by various forms of trade-based money laundering. A PWC report stated that 80 percent of illicit financial flows from developing countries are accomplished through trade-based money laundering. With sums of this magnitude, it is not surprising that banks, who are often the (unwitting) facilitators of this illegal activity, are coming under increasing pressure from regulators to take greater action to limit this growing international crime. For banks, TBML, disguised under the huge volumes of legitimate trade, is also extremely difficult to detect.