By: Georgette Virgo
In physical commodity trading, the paperwork behind a single shipment can pass through a dozen counterparties, several jurisdictions, and multiple currencies before a payment finally clears. Maxim Olkhovskiy, a Dubai-based Deputy CFO and commodity trade finance and treasury executive at Oasis Global Trading, has spent his career inside that chain, and his concern is direct: the industry often tries to reduce fraud risk by adding more documents, when the underlying problem is not always the absence of documents. It is the lack of visibility across the transaction as a whole.
In his Finextra opinion article titled “Why Trade Finance Fraud Needs Transaction Intelligence, Not More Documents,” Olkhovskiy, presented his expert analysis of trade finance fraud and advocated for transaction intelligence as a more effective solution than traditional document-based controls.
His central point is that, in physical commodity trading, fraud risk rarely sits inside one document alone. It more often appears in the relationship between documents, counterparties, shipment logic, payment behaviour, bankability and commercial rationale. In many transactions, no single participant sees that full picture at the right moment.
The Blind Spot Inside Every Trade File
That gap is structural, according to Olkhovskiy.
In a typical trade finance transaction, the bank issuing or confirming a letter of credit may not see the cargo. The treasury team managing liquidity does not physically inspect the goods. Compliance may not know the full commercial history of the counterparty. The trader closing the deal may not see the full banking, documentation and settlement chain behind it.
Each participant works with the evidence available to them. But those pieces of evidence are often designed to explain only one part of the transaction.
A set of documents can be technically complete and still fail to explain the underlying risk.
“Does the counterparty fit the transaction?” is one of the questions Olkhovskiy believes trade finance controls need to ask more explicitly. It is a simple question, but not one that can always be answered from a checklist. It requires understanding the relationship between the parties, the goods, the route, the financing structure, the payment terms and the transaction history.
That is the difference between checking documents and understanding a transaction.
Why More Paperwork Does Not Catch Better Fraud
Olkhovskiy’s piece draws on typologies documented by the Financial Action Task Force and the Egmont Group in trade-based money laundering cases: over- and under-invoicing, over- and under-shipment, phantom shipments, duplicated invoicing, and the use of shell companies to disguise a counterparty’s real identity. None of these patterns requires a forged document. They depend on a mismatch that only becomes visible once someone compares a document against everything around it.
He cites the UAE Financial Intelligence Unit’s own strategic analysis of trade-based money-laundering cases as a regional example of the same pattern. Cases the FIU has reviewed have included forged bills of lading and tampered invoices, as well as softer signals that accompany them: account turnover exceeding a company’s declared trading volume, invoice-to-payment mismatches, transactional activity out of proportion to a business’s visible footprint, and counterparties with little to no public presence. None of those signals alone proves fraud. Together, they describe a transaction that does not add up, which is precisely the kind of judgment a document checklist was never built to make.
The broader trade finance industry is undergoing a similar transformation. The International Chamber of Commerce (ICC) has highlighted the need to accelerate trade digitalisation and improve data sharing to reduce inefficiencies and strengthen trust across cross-border transactions. Meanwhile, the Asian Development Bank’s Trade Finance Gaps, Growth, and Jobs Survey continues to identify fraud risk, compliance requirements, and limited transparency as factors affecting the availability and efficiency of trade finance. Together, these developments suggest that financial institutions are increasingly complementing traditional document-based processes with digital tools, richer transaction data, and enhanced risk analytics to improve trade finance controls.
Taking The Argument Public
Olkhovskiy is also scheduled to share these perspectives at Energy Trading Week Middle East 2026 in Dubai, where he is an invited speaker on the Energy Trade Finance track. His participation includes the panel discussion, “Digitalising Trade Finance: From Paper to Platform,” as well as an individual presentation titled, “From Red Flags to Transaction Intelligence: How AI, Counterparty Intelligence, and Digital Audit Trails Can Strengthen Trade Finance Controls.”
The timing is relevant. Commodity trade finance is under pressure from volatile markets, higher working-capital demands, sanctions complexity, documentation risk and tighter bank scrutiny. In that environment, the cost of weak transaction visibility is not theoretical. It appears in delayed payments, trapped working capital, bank queries, disputed documents and settlement uncertainty.
Separately, Olkhovskiy is involved in the early-stage development of Valtis.io, a trade finance technology project focused on transaction intelligence, digital audit trails, and trusted settlement workflows for commodity trading. He is careful to frame it as early-stage work, not as a licensed financial institution, payment processor or replacement for traditional trade finance infrastructure.
His view of technology is practical rather than promotional and he claims that artificial intelligence can help extract terms from contracts, compare invoices against letters of credit, identify mismatches in names, dates, ports or quantities, summarise transaction files and flag unusual patterns. But AI cannot physically verify cargo, make false information true or replace commercial and compliance judgment.
At the core of Olkhovskiy’s analysis is a fundamental redefinition of the purpose of trade finance controls. Rather than relying solely on document verification to confirm that a transaction appears valid on paper, he argues that effective fraud prevention requires transaction intelligence evaluating whether a transaction is coherent in its entirety by assessing the parties involved, the expected movement of goods, and the corresponding flow of funds. According to Olkhovskiy, the commodity trading industry has historically depended on document based controls because transactional documents represented the only information shared among participants. However, as banks, trading firms, and technology providers increasingly have the ability to exchange contextual data in real time, he argues that greater use of transaction intelligence could complement traditional document-based controls as trade finance becomes increasingly digital. In his view, the most consequential frauds are not those involving missing documentation, but those in which inconsistencies between counterparties, commercial activity, and transaction flows go undetected.