Overview

• Treasury’s financial crimes unit issued an advisory and a Financial Trend Analysis on Aug. 28 urging U.S. institutions to detect use of Chinese money laundering networks by Mexico-based drug cartels.
• FinCEN reviewed 137,153 Bank Secrecy Act reports from 2020–2024 and identified approximately $312 billion in suspicious activity linked to suspected CMLN operations.
• Officials describe a cartel–CMLN arrangement driven by Mexico’s limits on dollar deposits and China’s outbound currency controls, creating demand for underground dollar exchanges.
• The publications outline methods including trade-based schemes, mirror transactions, shell companies, money mules, counterfeit PRC passports used to open accounts, and recruitment of bank insiders.
• Sector findings include more than $53.7 billion in suspicious real-estate activity, $766 million tied to 83 adult and senior care centers in New York, and filings referencing human trafficking, healthcare fraud, and elder abuse.