This paper provides an updated discussion on a) the challenges associated with the implementation of controls relating to the identification of DUG risk in trade finance transactions; b) the prevalent financial industry-wide approach to DUG; and c) the feasibility of potential controls for the effective identification of DUG.

Finally, it aims to summarise best practices and recommendations for FI engaged in trade finance, recognising that a variety of approaches hold validity based on the individual circumstances of respective institutions.

Similarly, it observes that no single solution or approach will be appropriate for all, while further recognising that blunt goods name screening approaches are often of limited effectiveness in isolation.

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