The misuse of trade finance to disguise the transfer of funds or value through the misrepresentation of prices of goods and services is a recognised money laundering typology with a body of discussion and guidance literature in existence on the subject.The challenges for financial institutions (FI) in identifying such price misrepresentation have been well documented. However, it remains a risk which FI continue to be cognisant of and which regulators continue to highlight along with the need to have in place appropriate controls and identification methods. For example, as noted in the UK Prudential Regulation Authority and Financial Conduct Authority ‘Dear CEO Letter’ on trade finance activity, published in September 2021. The letter draws out the need to assess and understand transaction specific risks to sufficiently perform due diligence such as additional pricing checks or the use of tools such as vessel tracking and independent document verification. For any FI to perform additional pricing checks, a basic requirement would be that the invoiced price is observed to be manifestly unusual and/or other unexplained risk indicators are evident to the transaction, i.e., a risk-based approach (RBA).