While it is not yet the norm，regulation and guidance in parts of Asia call for greater due diligence by financial services firms when it comes to international trade financing. Applied judiciously，such additional steps can insulate banks from financial sanctions risks (most notably from US regulators). It can also help prevent damage to their reputation – which can help keep domestic officials at bay.

Both Hong Kong and the Monetary Authority of Singapore provide general guidance relating to bank screening for controlled goods (e.g. military and/or dual-use) export control as part of a broader trade-based money laundering (TBML) prevention effort. Additionally，the Indian Banks Association has circulated similar，albeit non-public，guidance within the financial services industry there. Beyond controlled goods identification，these guidance documents also address the need to identify and rationalize the pricing of the underlying goods，and the ships' ports of call and route. They do not address the challenges of such checks，nor provide prescriptive guidance on the regulatory expectations – yet there are regulatory expectations.

While this increased level of diligence presumably has its roots in the 1MDB corruption scandal that directly touched both Hong Kong and Singapore as well as Malaysia，the pressure on governments from Abu Dhabi to Tokyo to enact similar regulatory requirements has not abated. Given the October 25，2018 Office of Foreign Assets Control (OFAC) designation of Singaporean entities involved in maritime shipments involving North Korea，and the Shipping Advisories it has issued with regard to evasive practices with regard to both  the Democratic People's Republic of Korea and Syria，it would not be unreasonable to see countries require more detailed checks of trade finance transactions，in order to safeguard their reputations as trustworthy nations trying to uphold international law.

And the US?