Overwhelmed and Understaffed: TBML Compliance in a Time of Expertise Shortage

Regulatory and AML burdens are growing, and banks are expected to screen transactions more thoroughly than ever. But the trade operations teams responsible for this are shrinking, aging, or overwhelmed, creating new risks and a new kind of crisis.

In the past installments of the series, “Trade, Technology & Compliance – Navigating a Changing Landscape”, we have been looking at the overall evolving risks in TBML, arising from geopolitical tensions and the increasing complexity of international trade. We have also looked at the heightened regulatory scrutiny around the world, and the shift in legislation to encourage trade digitisation. Each of those themes converges in one place: the operations floor of a trade finance department. 

Unfortunately, this is where desks are emptying faster than new chairs can be filled. More than a third of seasoned trade‑finance practitioners in Europe and North America are expected to retire within five years. A BAFT pulse survey revealed that nearly two‑thirds of banks already doubt their ability to maintain skilled trade operations teams through the end of the decade. At precisely the moment when geopolitical tension, supply‑chain complexity and regulatory scrutiny are raising the bar, we are watching our institutional memory walk out of the building.

The result is felt in every daily metric that matters to an operations manager: the team has to work harder, for longer hours, turnaround times for Letters of Credit stretch from days into weeks, and first‑level screening alerts pile up because no one has enough knowledge, nor confidence, to be able to dismiss them. The hidden cost is even larger—missed red flags for trade‑based money laundering or sanctions evasion that may only surface in a regulatory examination months later.

The question, making appearances at BAFT, and on several GTR panels this week: what do we do with the “trade finance brain drain”?

A simple answer is: capture what we already know before it departs. Every bank holds a store of “tribal knowledge” in veteran sixth sense: rule‑of‑thumb price checks for dual‑use goods, escalation lines for seemingly benign ports, the shortcut that reconciles a packing list with its certificate of origin in six clicks instead of sixty. Systematically recording that know‑how in living playbooks turns tacit wisdom into formal process assets that can be taught, audited and continually improved.

Preserving knowledge, however, means little if there is no fresh cohort to absorb it. Graduate recruitment programmes have become the lifeblood of leading trade banks, but the traditional two‑year apprenticeship, shadowing senior document‑checkers, learning by osmosis, is no longer enough. It takes much longer, and much more, to become a true expert. The job itself is also becoming less and less attractive to young talents, who are much less willing to do highly repetitive work, and instead look for more interactive opportunities.

All of this, at a time where banks are expected to screen more, and screen deeper into the supply chain. Knowing what to screen, and what to look for, requires experience. Decades of experience.

Sanctions screening and compliance checks today are not just about checking names against a list—it’s about understanding the full context of a trade transaction. Which port is a red flag? What vessel behavior is consistent with illicit activity? Is a certain commodity misclassified to evade export controls? These are questions that demand not just technical tools, but seasoned judgment. The kind of judgment that comes from years of pattern recognition, from having seen similar transactions play out in hundreds of ways.

Yet the level of expertise required is rising just as the pool of experts is shrinking. Meanwhile, regulators are expecting unprecedented depth of oversight. Financial institutions must now scrutinize every actor in a trade deal: buyer, seller, shipper, freight forwarder, port, vessel, even the physical route. Was the vessel’s transponder turned off near a high-risk area? Has it recently engaged in ship-to-ship transfers in a sanctioned region?

These aren’t hypotheticals; they’re live compliance concerns.

And all of it hinges on people who know what they’re doing. But those people are leaving.

As experienced staff retire or burn out, and fewer young professionals choose to enter the field, the gap between regulatory expectation and operational capacity is only growing. Tools can support decisions, but they can’t make them. At least not yet. In a compliance environment defined by nuance, context, and evolving threats, the biggest risk banks now face may not be in missing a red flag, but in not having the right person in the room to see it.

The expertise crisis, or the trade finance ‘brain drain’ deserves more attention than just an article. In the next piece, we will be looking at the issue beyond TBML, its drivers in details, and how it is affecting the whole landscape of international trade. Stay tuned!

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We are organising a webinar, "Solving the Expertise Crisis in Trade Finance", on the 28th of May. We would love to have you there! Register here.