⚖️ Legal notice
This checklist is intended solely for general information purposes and does not constitute legal, tax or compliance advice. Although the content has been carefully compiled on the basis of current laws and regulations, no rights may be derived from it. Always consult a qualified adviser for your specific situation.
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Sanctions list screening
Trade structure analysis
Risk assessment
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STEP 1 · Check the invoice
Does the price match the market value? Verify this via a public source (UN Comtrade, industry website) or your own quotation history.
Is the invoice description specific? Vague descriptions such as "goods" or "services" without further specification are a red flag.
Does the invoiced weight/volume match the realistic size of the order?
Has your client requested changes to the price or description — without a clear business reason?
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A price deviating more than 20% from market value without explanation = strong red flag for over- or under-invoicing. Use UN Comtrade for a free price comparison by goods category.
STEP 2 · Verify the goods and documents
Do the goods in the shipment match what is stated on the invoice and transport document?
Is a Bill of Lading or CMR waybill present — and are they consistent with the rest of the documentation?
Is there only one invoice per shipment? Multiple invoices for the same shipment are a direct red flag.
Have the goods actually been sent or received, or was this "on paper" without any physical flow?
Is the chosen transport route the most logical and economically justified route for this type of goods? A detour via an unusual transit country without explanation is a red flag.
Does the shipment involve dual-use goods — products usable for both civilian and military purposes (such as certain electronics, chemicals or optical equipment)? Are these being shipped to countries known as transit hubs to sanctioned regions?
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Missing or inconsistent transport documents = possible phantom shipping or multiple invoicing.
STEP 3 · Investigate the trading partner
Does the buyer or seller have demonstrable business activity (website, company registration or equivalent, visible staff)?
Is the party based in a normal country for this type of trade, or in a Free Trade Zone or offshore jurisdiction?
Is none of the parties involved on a sanctions list (EU FSF, OFAC SDN, UK Sanctions List)?
Are the contact persons identifiable and consistent across repeated transactions?
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No demonstrable business activity + offshore address + unknown UBO = elevated TBML risk.
STEP 4 · Analyse the money flow
Does the payment come from the contracting party itself — or from an unknown third party?
Is the payment route logical (country of payer = country of buyer, unless there is a clear group structure)?
Is the amount exactly equal to the invoice value, or are there unexplained additions or deductions?
Has the payment been split into multiple smaller amounts each falling below a reporting threshold?
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Payment via third party + split amounts + offshore route = a combination requiring immediate further investigation.
STEP 5 · Assess the overall picture
Do you yourself understand how the complete trade chain works: who buys, who delivers, who pays, and why via this route?
Can you explain the transaction to your bank, accountant or regulator without it sounding forced?
Is there no time pressure? Pressure to sign quickly without asking questions = a classic manipulation signal.
Are there no near-identical transactions with constantly changing party names or addresses?
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If you cannot explain the chain, you cannot defend it either. Always document everything in a file.
🚨 STOP IMMEDIATELY — do NOT accept the transaction if:
- ⛔The price on the invoice is far from market value — and your client provides no explanation.
- ⛔The goods on the paperwork do not exist or demonstrably do not match the shipment.
- ⛔The same shipment is invoiced multiple times to you or to another party.
- ⛔There is no physical goods flow but a fully paid invoice (phantom shipping).
- ⛔The payment comes from an unknown party with no demonstrable relationship to your client.
- ⛔You are experiencing pressure to deliver or sign quickly without time for verification.
Unsure about a trading partner or transaction?
Verification of your trading partner
Goods flow analysis
Sanctions check on all parties
👉 Request a KYC report →
Bank-grade KYC report · Within 48 hours · Professional & independent