ADB’s Trade and Supply Chain Finance Program (TSCFP) is working with banks, regulators, and others to improve the quality of data in suspicious transaction reporting to help fight against trade-based money laundering. TSCFP is working with the United Nations Office on Drugs and Crime (UNODC) on its goAML suspicious transaction reporting system that has been adopted by more than 60 countries. Antoine Karam from UNODC’s Information Technology Service talks about the importance of data in countering trade-based money laundering and his experience working with ADB.


What is the UNODC’s GoAML software and describe the partnership with the ADB?

My name is Antoine Karam, I’m the Chief of the Software Products for Member-States Unit. I generally oversee the United Nations Office on Drugs and Crime (UNODC). This unit develops and maintains software that serves the mandates of UNODC in fighting financial crime or money laundering, tourist financing, drug trafficking, and other areas that fall under the mandates and thematic pillars of the UNODC. 

One of our main software is GoAML. It is used by hundreds of thousands of users in the world and close to 70 member states, to date. This software is an integrated solution for Financial Intelligence Units to help them analyze data, collect and analyze data, find actionable intelligence, and disseminate this information to prosecution. 

We were approached by the Asian Development Bank a couple of years ago related to an effort that they were leading to combat TBML – Trade-Based Money Laundering. The effort did not have enough traction, was not having effective actions, and the objective was to be able to report more precisely on crimes related to TBML in the Asia-Pacific region, and also to have a much more effective action against this crime. 

And soon enough, the Asian Development Bank had approached several member states and identified 5 to 7 member-states that had a lot of interest and that had a lot of stakes in having these features developed for them to be able to report and combat better this form of crime. 

What are the implications of TBML to trade and supply chains?

TBML is a sort of a financial crime that has global repercussions. It is precise and particular because of the granularity, because of the channels that they take place, because of the specifics related to containers, shipment of information, and because of the long queues of supply chains, and trade chains where it can happen. 

For a crime like this to be detected, there needs to be a very precise strategy that targets these particularities. And it needs to be designed by subject matter experts from Financial Intelligence Units and regulatory bodies, and perhaps the Asian Development Bank, for example, to be able to have it effectively eliminate this crime. 

How is GoAML governed?

The software GoAML is governed through a mechanism of several platforms where financial intelligence units submit the features that they wish to have, vote on the strategy of the product, the direction, and the releases.  It’s part of a large scope of governance and policies, shared by the FIU of Luxembourg – the current Chair of the regional committee of GoAML. 

Therefore, I informed the ADB of this and soon enough there were 7 FIUs that have expressed strong wishes to have features related to TBML and particularly designed with all granularities and all the preciseness needed in containing information in shipping and supply chain for reporting to become effective related to TBML crimes. 

Those FIUs, after a few workshops, organized by the ADB in which we have participated as well, have expressed precisely what their wish was. And these functionalities were designed inside GoAML. Today, we have instantly after having developed these features, we have released the latest version of GoAML that has these features and they are accessible to 70 member-states. 

Describe the early successes of working with ADB

Working with the Asian Development Bank has been an experience that was quite significant for me and us in the last couple of years. 

If it wasn’t for a flexible model of governance, there was no way that an external party that belonged to different, perhaps sectors,  or maybe even the private sector, would be able to have an impact in the features and the design, and the strategies of this product. 

When I worked with the ADB closely on these things, I found a new horizon, I found the impact of public-private partnerships, I found the relevance of their work, and I have found that it was very important for me, for our product to listen to some of their needs, and some of their requirements, coming from this direction as well, not only from Financial Intelligence Units. That is the lesson for me and that is the success of being open-minded and ready to have several persons sit on the table and work as much as possible for the general good, and it attempts to fight financial crime and, in this case, TBML.