Customs data to identify trade-based money laundering
Source: gov.uk (2025-10-29)

Case study of use of customs and other data.

Case study: operation A, use of customs and other data

HMRC’s International Trade team were able to provide evidence that the UK companies did not ship the declared goods as detailed on the paperwork. The team scoured HMRC databases to find any company Economic Operators Registration and Identification (EORI) numbers. This number is required by all companies when moving goods into or out of the UK, as it allows HMRC to collect the duty on the goods. This enquiry confirmed, with submittable evidence, that of all eight companies and their associated directors and addresses searched on the MSS system, none of the entities had applied for an EORI, and none of the entities had made an import declaration.

Enquiries surrounding the businesses confirmed they were operated from serviced offices. There was no evidence of warehousing in the UK, transport logistics or shipping for the purported goods, which might support legitimate trade.

Enquiries with HMRC VAT systems and VAT experts evidenced that some of the companies were not registered for VAT. Those which did register for VAT had been previously investigated, considered non-compliant and subsequently de-registered for VAT. VAT experts within HMRC were able to provide witness statements and oral evidence to support the prosecution case.

These companies had also previously been suspected to be involved in Missing Trade Intra-Community fraud (MTIC). The case team felt the MTIC fraudsters had moved into trade-based money laundering, using the company structures already in place from the MTIC fraud to conceal the proceeds of crime within the white noise of the trade sector.

The VAT Exchange system, VIES provides information relating to the value of goods or services supplied between VAT registered businesses in different member states in the EU. The data on this system is gathered from the completed EC Sales List (ESL) and stored data is exchanged between member states on a quarterly basis. Searches in this case included a search on VIES and showed no trade was identified.

Enquiries with European countries that featured on the fictious documents evidenced that these companies had a history of non-compliance and were under investigation by their own tax authorities. These enquiries also confirmed the businesses were involved in fictitious trading.

The case team also made enquiries on the high value dealer database. This demonstrated one of the companies had made an application to trade as a high value dealer, however following a request from HMRC for additional information to complete the application, the requested information was never received, and the registration was never completed. All other companies in this case were not registered as high value dealers.

In this case the investigation team utilised International Mutual Assistance (IMAT) to obtain information from European counterparts. This included evidence from the Czech Republic concerning the cost of Red Bull soft drinks and its potential movement from the UAE for re-sale.

There are numerous systems available to interrogate and understand legitimate movements of freight. By identifying normal activity, this will highlight unusual activity which, in turn, will provide that point of entry to start targeting TBML. In the case study above, investigators used the International Trade Division within HMRC, however there are a number of other sources available via your customs administration, which you might also want to explore during your investigation.

Data systems and benefits to the investigation

Customs Declaration System

A system which supports the international trade sector to make a declaration. Data includes commodity codes, useful for targeting.

Shipping Manifest Data

Lists all items which have been shipped. Can be used to track items and verify items were received. Using this data may demonstrate mis-invoicing, over or under valuation of goods or evidence of phantom shipments.

Bill of Lading

Ownership of the goods. This will provide the shipper and consignee name and address, description and quantity of goods, date and method of shipment. This may be useful when targeting shipments and or looking to house subjects.

Economic Operators Registration and Identification (EORI) Number

Used in operation A. Required by all companies when moving goods into or out of the UK. If this number is absent, it is unlikely any goods have been shipped, inferring phantom or fictitious shipments.

Trade Tariff

Data includes commodity codes, import and export controls, customs duty and VAT rates. This information may assist to identify anomalies.

Goods Vehicle Movement System

The GVMS links to the Customs Declaration System and Declaration Management System (Bolt) which allows the user to search for traders using the EORI number or the name and address of the trader. A search on the EORI will also show the haulier, the haulier address, contact names, telephone number and email address.

Declaration Management System

This system holds details of the invoices and associated weights of the items being shipped, allowing identification if the weight of the load is more or less than should be expected.

Anti-Fraud Information System (AFIS)

This system enables analysis, providing a search facility on the vehicle details, carrier name, company address, consignee name, principal name, declaration type, commodity codes, descriptions, customs office of destination and departure and country of origin. AFIS also lists the countries a vehicle is due to be transiting through.