FinCEN Advisory on Chinese Money Laundering Networks
In case you missed it, FinCEN issued an Advisory (FIN-2025-A003) urging financial institutions to be on the alert for transactions related to the use of Chinese money laundering networks (CMLNs). Such CMLNs operate around the world as professional money launderers and are a key component to laundering drug and other illicit proceeds in the United States for Mexican-based cartels. A 2024 National Money Laundering Risk Assessment by the Treasure states that CMLNs are one of the most significant money laundering threat actors facing the U.S. financial system.
The Advisory includes 18 potential red flags to help financial institutions maintain awareness. These would be a good place to start when training your Team.
FinCEN requests that financial institutions reference this Advisory in SAR field 2 (Filing Institution Note to FinCEN) and the narrative by including the key term “CMLN-2025-A003” and select, as applicable, SAR field 38(n) (Suspicious Use of Informal Value Transfer System); SAR field 38(s) (Unlicensed or Unregistered MSB); SAR field 36(l) (Trade Based Money Laundering/Black Market Peso Exchange), and any other applicable check box.
Amy Kudlacek
Amy brings many years of banking and compliance experience to Banker’s Compliance Consulting. She has worked for both large and small financial institutions and spent time working in every area of a bank. She started out as a teller in college and eventually became a branch manager. Her love, however, was always compliance. Amy began her career with Banker’s Compliance Consulting in 2000. Her knowledge and experiences have allowed her to develop a well-rounded and practical approach to regulatory compliance. Amy is CRCM certified, has a Bachelors Degree in Business Administration and is a graduate of the ABA Compliance School. Amy & her husband have two children at home and stay busy following their activities. They spend a lot of time in the bleachers!