TCAE is excited to invite Ross Delston, Attorney and Expert Witness, and Kim Manchester, Managing Director of ManchesterCF to share their insights on Trade-Based Money Laundering (TBML) Join us to consider, discuss and debate the dilemma arising from TBML that banks face: that there is never enough Customer Due Diligence (CDD), Enhanced Due Diligence (EDD), Extra Enhanced Due Diligence (E2D2), Know Your Customer (KYC), and Know Your Customer’s Customer (KYCC) processes and procedures to detect, report and/or mitigate instances of trade-based money laundering.

We will also discuss how it isn’t just banks but also money services businesses (MSBs), hawaladars, cash couriers, and anyone else who transmits, transfers or carries money across borders who face this dilemma. And all those in the supply chain also may be affected by TBML. Join this session to find out about some of the practical tools that financial institutions (FIs) can use to combat this constant and continuing threat.


  • Why FIs face such distinct disadvantages when confronting TBML
  • Why pandemic pricing and price volatility are a launderer’s strongest ally
  • Why letters of credit and standby letters of credit can be so effective in disguising money laundering
  • What used cars, charcoal and gold have in common when it comes to TBML


Ross Delston | CAMS, Attorney + Expert Witness
Ross Delston is an independent American attorney, expert witness, and former U.S. banking regulator (FDIC) who has specialized in AML/CFT issues for over 20 years. Ross has participated in the monitorships of AIG and BNP Paribas, and has been a consultant to the IMF on AML/CFT and banking matters since 1997. On behalf of the IMF, he has participated in nine AML/CFT assessments of offshore financial centers, including Jersey, Bermuda, and St. Vincent. Ross has also been an expert witness on AML issues in 15 cases, including on behalf of plaintiffs in Joint Liquidators of Stanford International Bank. v. Toronto-Dominion Bank, a Canadian civil action growing out of one of the largest Ponzi schemes in recent history.
Ross has drafted trade finance policies and procedures to address TBML risks for a multinational bank and conducted training on the new procedures. He has also co-authored two law review articles on TBML: “Strengthening Our Security: A New International Standard on TBML is Needed Now” (2012) and “Reaching Beyond Banks: How to Target TBML and Terrorist Financing Outside the Financial Sector” (2009). Ross started his career as an attorney at the U.S. Export-Import Bank where he drafted and negotiated trade finance deals.
Ross has been quoted on AML/CFT and banking issues in the New York Times, Washington Post, Wall Street Journal, New Yorker, the American Banker, Bloomberg, ICIJ, OCCRP, the Times of London, the Nikkei (Japan) and the Hindu Business Line (India). He has lectured and conducted training on AML/CFT and TBML topics at the U.S. Financial Crimes Enforcement Network (FinCEN); the Peoples Bank of China (central bank) twice; the Reserve Bank of India’s Staff College in Chennai; for U.S. bank examiners at the 2016 FFIEC Advanced BSA/AML Specialists Conference; and at conferences and seminars throughout the world.

Kim R. Manchester | Managing Director of ManchesterCF
After a decade of working in international banking in Asia, Kim Manchester founded ManchesterCF in 2004. Based in Toronto, ManchesterCF provides online financial intelligence training programs to financial institutions, financial intelligence units and law enforcement. The Financial Intelligence Specialist designation is offered to compliance professionals around the world exclusively through ManchesterCF. Kim has spoken at financial crime compliance conferences in North America, UK/Europe, Asia and the Caribbean.


Souzan Esmaili, Compliance & AML Consultant | Founder, TCAE
Souzan Esmaili has over 15 years of international experience in consultancy and training with a focus on Regulatory Compliance, Anti-Money Laundering, Anti-Bribery and Corruption and RegTech. She worked for various financial institutions and consultancies in Dubai and Toronto.In Toronto, she worked with one of the international banks and covered their Anti-Bribery and Corruption program for Canada and Latin America.
Prior to moving to Canada, Souzan worked as a senior consultant and assisted her clients to understand their compliance needs, advised on meeting regulatory requirements and managed a multitude of remediation projects. She has acted as the Compliance Officer and MLRO for a number of firms regulated by the Dubai Financial Services Authority (DFSA) and advised extensively on matters related to Governance, Risk and Compliance (GRC).
In October 2019, Souzan created Toronto Compliance and AML Events (TCAE) with a passion to help the AML and Compliance professionals to connect and inform them of relevant events based in Toronto. In March 2020, Souzan launched The Knowledge Series where she brings international industry experts and thought leaders to share their knowledge and experience with the AML and Compliance professionals around the world.