September 8, 2025
On August 28, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an Advisory and Financial Trend Analysis on Chinese money laundering networks (CMLNs).
Chinese money laundering networks pose a significant threat to the U.S. financial system. FinCEN’s Financial Trend Analysis highlights the scope and breadth of CMLN activity in the United States. FinCEN analyzed 137,153 Bank Secrecy Act (BSA) required Suspicious Activity Reports filed by financial institutions between January 2020 and December 2024 that described suspected CMLN-related activity, totaling approximately $312 billion in suspicious transactions.
Below are highlights from the reports:
What are CMLNs?
- CMLNs are professional money laundering networks that are based in the People’s Republic of China (PRC), the United States, or other parts of the world. As discussed in the Advisory, CMLNs are often used by Mexico-based cartels to launder drug proceeds into the U.S.
- CMLNs often recruit private individuals who carry passports from the PRC to play a role, wittingly or unwittingly, in these networks to launder money across the globe.
- Chinese citizens’ demand for large quantities of U.S. dollars and cartels’ need to launder illicit U.S. dollar proceeds has resulted in a mutualistic relationship wherein cartels sell off illicitly obtained U.S. dollars to CMLNs who, in turn, sell the U.S. dollars to Chinese citizens seeking to evade China’s currency control laws.
CMLNs May Recruit Employees Inside Financial Institutions.
- CMLNs often utilize trade-based money laundering, money mules, and online mirror transaction methodologies involving fake trading platforms.
- CMLNs may recruit financial institution employees to act as insiders or infiltrate and place CMLN members within a financial institution to assist in money laundering schemes.
- CMLNs may also provide money mules with counterfeit Chinese passports to facilitate account opening and other illicit financial behavior.
CMLNs Favor Real Estate Purchases for Money Laundering.
- As discussed in the Financial Trend Analysis, financial institutions filed 17,389 SARs between 2020 and 2024 associated with more than $53.7 billion in suspicious activity involving the real estate sector.
- CMLNs may use money mules, like Chinese investors, or shell companies to purchase U.S. real estate with laundered funds.
Please read FinCEN’s full Advisory and Financial Trend Analysis for a comprehensive list of red flag indicators.
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FinCEN requires financial institutions to file a SAR if it knows, suspects, or has reason to suspect a transaction conducted or attempted by, at, or through the financial institution involves funds derived from illegal activity. A SAR can be accessed through the Bank Secrecy Act (BSA) E-Filing System.
If you believe you have witnessed a suspicious activity involving money laundering, we encourage you to contact a Whistleblower lawyer, who focuses on FinCEN-related matters.
About the Author
Christina McGlosson, special counsel in Cohen Milstein’s Whistleblower practice, focuses exclusively on Dodd-Frank Whistleblower representation. She is the former director of the Whistleblower Office in the Division of Enforcement at the U.S. Commodity Futures Trading Commission. She was also a senior attorney in the SEC’s Division of Enforcement, where she assisted in drafting the SEC rules to implement the whistleblower provisions of Dodd-Frank. She also served as Senior Counsel to the SEC’s Director of the Division of Enforcement, and Senior Counsel to the SEC’s Chief Economist.
Christina represents whistleblowers in the presentation and prosecution of fraud claims before the SEC, CFTC, FinCEN-, as part of the U.S. Treasury, the Department of Justice, and other federal government agencies.
Christina McGlosson, Special Counsel: Dodd-Frank Whistleblower Practice
Cohen Milstein Sellers & Toll PLLC
1100 New York Avenue, NW
Washington, DC 20005
E: cmcglosson@cohenmilstein.com
T. 202-988-3970
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