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TBML002U · TBML

Under Invoicing

Is a trade transaction being used to transfer value through invoice deflation below expected market value — understating the price to move value to the importer, evade duty, or settle an obligation outside the visible trade?

Under Invoicing occurs when the value of goods or services on an invoice is intentionally understated below their true market value. It is the mirror of over-invoicing: where over-invoicing moves value to the *exporter* through overpayment, under-invoicing moves value to the *importer* — the buyer receives goods worth far more than the price paid, and the difference is settled or realised outside the visible trade.

It is used to:

Risk narrative

A customer imports goods from a counterparty at a price materially below the market benchmark. The trade documents are internally consistent, but the declared value cannot be reconciled with the commodity's benchmark price. The value gap accrues to the importer; it may be settled through a separate channel, netted against an unrelated obligation, or simply realised on resale at market price. Where the counterparty is a shell and the parties share ownership, the under-price is not a commercial discount — it is a transfer mechanism.

Risk indicators

Risk

Investigation actions

  1. Reconcile the declared unit price against the benchmark; confirm the commodity,
  2. Quantify the value gap and establish where it accrues.
  3. Assess counterparty commercial substance; test for shell indicators.
  4. Resolve ownership; test for shared directors / owners and related-party trade.
  5. Trace the payment trail for netting, split or third-party settlement.
  6. Package evidence for investigator review where the score is High or above.

Use cases

Related typologies

TBML001TBML003TBML005TBML009TBML010TBML011

Curated from fc-04-tbml-analytics-toolkit/typologies/TBML002/TBML002_Under_Invoicing.md