FinCEN Issues Advisory on Chinese Money Laundering Networks

Key takeaways from the announcement include:

➡️ Between 2020-2024, $312b of suspicious transactions filed under Bank Secrecy Act (BSA) reports were associated with CMLNs;

➡️ CMLNs are often linked to other forms of illicit activity, with 1,675 reports in the same period indicating potential links to human trafficking or smuggling;

➡️ CMLNs may target high-value markets and leverage investors with strong US real estate interests to support the laundering process; and

➡️ CMLNs use a wider array of methods to launder proceeds, including trade-based money laundering (TBML), money mules, and mirror transaction methodologies.

✅ Firms operating in the US should review the red flags catalogued in the notice, and incorporate them into their typology registers to ensure their controls are responsive to an evolving global risk landscape.