This is an Insight article, written by a selected contributor as part of GIR's co-published content. Read more on Insight
Money laundering is the lifeblood of organised crime. Without the ability to move, conceal and integrate illicit proceeds into the legitimate financial system, criminal enterprises – from drug cartels to cyber fraud rings – would be severely constrained in their reach and impact. Recognising this, the US Department of Justice (DOJ or the Department) serves as the principal federal authority responsible for prosecuting criminal violations of anti-money laundering (AML) laws, including the Bank Secrecy Act (BSA) and the Money Laundering Control Act (MLCA).[1] For the Department to bring a criminal prosecution, it must establish a wilful violation of the relevant statute – meaning the government must demonstrate that the defendant had knowledge that the conduct was criminal, though courts have held that wilful blindness cannot serve as a defence.[2] On the civil side, the Financial Crimes Enforcement Network (FinCEN), a bureau within the Department of the Treasury (the Treasury), is charged with pursuing civil violations when financial institutions violate the BSA.
Because the DOJ is led by the Attorney General (AG), a presidential appointee, the Department’s enforcement priorities inevitably shift across administrations, reshaping the landscape of prosecutorial focus and the types of cases that receive the most resources and attention. The current Administration has been especially unequivocal about its priorities. As Matthew R Galeotti, the head of DOJ’s Criminal Division, stated at an Anti-Money Laundering and Financial Crimes Conference in May 2025: “The deadly activities of cartels and [transnational criminal organizations] are enabled by international money laundering organizations and other financial facilitators. Illicit financial and logistical networks undermine our national security by facilitating sanctions evasion by hostile nation-states and terror regimes.”[3]
Now in its second year, the Trump Administration’s DOJ has continued to sharpen its enforcement posture. A review of the Department’s actions over the past year reveals several distinct trends in the prosecution of AML violations:
- particularly significant emphasis on cartels and transnational criminal organisations (TCOs);
- increased focus on Chinese money laundering networks;
- no regulation by prosecution for digital assets; and
- attention to the role of bank insiders in money laundering operations.
This chapter examines each of these trends in detail, drawing on key prosecutions, policy memoranda and public statements from senior DOJ officials to illustrate the Department’s evolving enforcement posture. It also addresses the parallel trajectory of civil AML enforcement, which the Treasury has largely scaled back, a notable counterpoint to the DOJ’s aggressive criminal docket.
Cartels and TCOs
From the earliest days of the new Administration, the DOJ has devoted significant resources and attention to prosecuting cartels and TCOs, making this category of enforcement the defining hallmark of the current Department. This priority has been communicated through both sweeping policy memoranda and a steady stream of high-profile prosecutions.
On 5 February 2025, former AG Pam Bondi released a memo to all DOJ employees regarding the “total elimination” of cartels and TCOs.[4] Former AG Bondi’s language was direct and urgent: “[W]e must harness the resources of the Department of Justice and empower federal prosecutors throughout the country to work urgently with the Department of Homeland Security and other parts of the government toward the goal of eliminating these threats to U.S. sovereignty.”[5] Marking a decisive shift in priorities from the Biden Administration, the memo called for Task Force KleptoCapture,[6] the DOJ’s Kleptocracy Team, and the Kleptocracy Asset Recovery Initiative to be disbanded, with all resources previously devoted to those efforts to be redirected toward the “total elimination of cartels and TCOs”.[7]
The DOJ further showcased its priority through the creation of Operation Take Back America, under which many of its AML prosecutions now fall. Operation Take Back America is a “nationwide initiative that marshals the full resources of the Department of Justice to repel the invasion of illegal immigration, to achieve the total elimination of cartels and transnational criminal organizations, and to protect our communities from the perpetrators of violent crime”.[8] The details of the Operation were announced to Department employees in a memo from Deputy Attorney General (DAG) Todd Blanche on 6 March 2025.[9] The cases discussed below were brought as part of this this Operation.
One illustrative case from 12 December 2025, involves a Florida resident, Alain Bibliowicz Mitrani, who laundered over US$300 million, predominantly derived from drug proceeds.[10] Bibliowicz Mitrani was convicted by a federal jury in Brooklyn on charges of money laundering conspiracy, bank fraud conspiracy, conspiracy to operate an unlicensed money transmitting business and operation of an unlicensed money transmitting business, all related to his laundering of drug proceeds through US financial institutions.[11] Bibliowicz Mitrani owned a technology business that served as a front for a money laundering operation spanning Florida and Colombia.[12] By establishing shell entities to open bank accounts, Bibliowicz Mitrani laundered proceeds on behalf of cartels and other TCOs, including the Sinaloa Cartel.[13] He now faces up to 70 years in prison.[14] Prosecutors were unambiguous about their intentions to dismantle money laundering schemes supporting drug cartels. As Ricky J Patel, Special Agent in Charge of Homeland Security Investigations in New York, stated: “Our message to money launderers is clear: if you think you can bankroll drug cartels and criminal enterprises from the shadows, we will find you, expose you, and shut you down.”[15]
The case against Cristian Fernando Gutierrez-Ochoa, leader of the Cártel de Jalisco Nueva Generación (CJNG), also exemplifies the DOJ’s commitment to prosecuting money laundering committed by cartels.[16] Gutierrez-Ochoa, of Michoacán, Mexico, laundered millions of dollars for CJNG and used part of the proceeds to buy his residential house in Riverside, California.[17] Ultimately, Gutierrez-Ochoa pled guilty to conspiracy to launder CJNG’s drug proceeds.[18] On 18 December 2025, Gutierrez-Ochoa was sentenced to 140 months in prison and three years of supervised release.[19] As part of his guilty plea, he forfeited the California residence, US$2.2 million in bulk cash found at the house, and other items of value in the residence.[20]
Notably, the Department is not confining its focus to cartel leadership; it also is pursuing individuals at every level of the money laundering chain, signalling that no participant is too small to escape scrutiny. For example, a brother and sister from Ohio, Christopher Grover Reynolds and Claudette Reynolds, were sentenced in August 2025 for participating in a money laundering conspiracy.[21] Christopher helped collect drug proceeds in Toledo, Ohio, from the sale of fentanyl, methamphetamine and marijuana, then either transferred those proceeds to a cartel in Mexico or personally delivered – or had Claudette deliver – the money.[22] Although the siblings did not play as significant a role in the money laundering scheme as the defendants in the two previously discussed cases, Galeotti underscored the importance of their prosecution: “Their money laundering activities fueled the importation of dangerous drugs into the Midwest. This prosecution reflects the Criminal Division’s commitment to staunch the flow of cash to cartels and protect communities from the devastating consequences of drug trafficking.”[23]
In light of the DOJ’s aggressive targeting of cartels and TCOs, US businesses should proactively conduct enhanced due diligence on their business counterparties to ensure they are not inadvertently facilitating or supporting a cartel or TCO. As a foundational measure, US companies should strengthen their AML compliance programmes and ensure that robust know-your-customer (KYC) procedures are in place. Financial institutions, in particular, should closely monitor transactions that present a heightened risk of money laundering tied to cartels, including cross-border wire transfers, structuring patterns and large cash transactions in border regions. This includes complying with the Geographic Targeting Order (GTO) issued by FinCEN on 8 September 2025.[24] The GTO requires money services businesses to file currency transaction reports for cash transactions between US$1,000 and US$10,000 occurring in certain geographic locations in Arizona, California and Texas.[25]
Chinese money laundering networks
The DOJ has also turned significant attention to Chinese money laundering networks (CMLNs), which sit at the intersection of two of the Administration’s highest-priority enforcement targets. The Department has pursued CMLNs through two distinct lenses: (1) their role in laundering drug proceeds on behalf of cartels and TCOs; and (2) their role in facilitating online romance scams, commonly known as “pig-butchering” schemes.
First, the DOJ has explicitly listed “[c]omplex money laundering, including Chinese Money Laundering Organizations, and other organizations involved in laundering funds used in the manufacturing of illegal drugs” as one of 10 priorities in a memo from Galeotti to all Criminal Division personnel in May 2025.[26] The focus on CMLNs is not limited to the DOJ, as FinCEN released an advisory on the use of CMLNs by Mexico-based TCOs.[27] The advisory names CMLNs as “one of the most significant money laundering threat actors facing the U.S. financial system”.[28]
One notable prosecution involved two individuals sentenced for working with a Chinese money laundering organization that laundered funds on behalf of the Sinaloa Cartel, CJNG and other cartels.[29] Li Pei Tan, a US national, and Chaojie Chen, a Chinese national residing in the United States, collected proceeds from the sale of fentanyl and cocaine across the country and then coordinated with co-conspirators to “clean” the money by purchasing electronics and shipping them to China.[30] The scheme resulted in millions of dollars being laundered; at just one point in time, law enforcement caught Tan in possession of US$197,000 in cash.[31] Tan was sentenced to 78 months in prison, and Chen was sentenced to 90 months.[32]
Another prosecution from early 2026 involves Yan Lin, a California resident who was charged with conspiracy to commit money laundering and concealment money laundering.[33] Lin allegedly collected proceeds from the sale of fentanyl, cocaine and methamphetamine across the United States and then coordinated with co-conspirators to use those funds to purchase electronics and ship them to Hong Kong.[34] In 2024 alone, only a portion of Lin’s laundering transactions totalled US$27.4 million.[35] US Attorney Dominick S Gerace II explained the rationale for prosecuting Lin: “These profiteers help facilitate the distribution of deadly drugs into our communities and will be held accountable as if they trafficked the drugs themselves.” If convicted on both charges, Lin faces a maximum sentence of 20 years in prison.[36]
Second, in the latter half of 2025, the DOJ began aggressively targeting the use of pig-butchering scams as a vehicle for money laundering – a rapidly growing area of concern that has prompted the creation of dedicated institutional infrastructure. This enforcement push is illustrated by the prosecutions discussed below and the establishment of the new Scam Center Strike Force.[37] On 12 November 2025, US Attorney for the District of Columbia Jeanine Pirro announced the creation of the District of Columbia Scam Center Strike Force.[38] The Strike Force represents a collaborative effort among the DOJ’s Criminal Division, the FBI and the US Secret Service, underscoring the multi-agency commitment to combating these schemes. [39]
As the Scam Center Strike Force press release explains, pig-butchering schemes are typically operated out of “scam compounds” located in Southeast Asia.[40] These scams target “everyday Americans” by cultivating the trust of victims over time and then convincing them to invest in fraudulent cryptocurrency platforms, after which the funds are laundered into accounts outside of the United States.[41] The scale of the problem is staggering: the DOJ reports that pig-butchering scams result in Americans being defrauded of nearly US$10 billion per year.[42]
Perhaps the most striking case example is from 14 October 2025, which resulted in the DOJ’s largest-ever forfeiture action, valued at US$15 billion in bitcoin.[43] Chen Zhi, a Cambodian national, is the founder and chairman of Prince Holding Group.[44] Publicly, Prince Group presents itself as a real estate development, financial services and consumer services company.[45] In reality, however, the company serves as a cover for pig-butchering scam compounds operated across Cambodia, constituting what the DOJ has called “one of Asia’s largest transnational criminal organizations”.[46] Adding an additional layer of criminality, these compounds were staffed by trafficked forced labourers.[47] While Prince Group defrauded victims around the world, the DOJ has identified at least one network within the organisation that scammed millions of dollars from over 250 victims in New York and across the United States.[48] The indictment of Chen Zhi resulted from coordinated action among the DOJ, FinCEN, the Office of Foreign Assets Control (OFAC), the Drug Enforcement Administration (DEA) and the United Kingdom’s National Crime Agency.[49] If convicted, Chen Zhi faces up to 40 years in prison.[50]
The DOJ also seized three web domains used to defraud victims through pig-butchering schemes in December 2025.[51] The domains were linked to the Tai Chang scam compound, located in a village in Burma.[52] Notably, this operation to dismantle the Tai Chang compound involved collaboration with the private sector as well: Meta coordinated with the Strike Force and voluntarily removed approximately 2,000 accounts associated with the compound from its platforms.[53]
Consistent with the recommendations above regarding cartels and TCOs, US businesses should conduct thorough diligence to ensure that the parties with whom they transact are not Chinese money laundering organisations or fronts for pig-butchering scams. Financial institutions should pay particular attention to FinCEN’s advisory, which identifies specific red flags for detecting suspicious activity related to CMLNs, including unusual trade-based transactions, rapid movement of funds through multiple accounts and transactions involving jurisdictions known for CMLN activity.[54]
No “regulation by prosecution” for digital assets
Following President Trump’s lead,[55] the DOJ has fundamentally shifted its approach to prosecutions in the digital assets industry – moving away from the prior Administration’s aggressive posture toward a more targeted framework that distinguishes between wilful bad actors and regulatory noncompliance. As President Trump directed, “[w]e are going to end the regulatory weaponization against digital assets”, and the DOJ has followed suit.[56] In a memo to all DOJ employees dated 7 April 2025, DAG Blanche articulated the Department’s new enforcement posture: “[T]he Department's investigations and prosecutions involving digital assets shall focus on prosecuting individuals who victimize digital asset investors, or those who use digital assets in furtherance of criminal offenses such as terrorism, narcotics and human trafficking, organized crime, hacking, and cartel and gang financing.”[57] Galeotti reinforced these directives at the American Innovation Project Summit on 21 August 2025: “As the DAG’s memo makes clear, the Justice Department will not charge regulatory violations in cases involving digital assets—like unlicensed money transmitting under 1960(b)(1)(A) or (B)—in the absence of evidence that a defendant knew of the specific legal requirement and willfully violated it.”[58]
President Trump also has utilised his pardon power to signal the Administration’s new stance toward digital assets. On 27 March 2025, President Trump pardoned three founders and a top executive of BitMEX,[59] a cryptocurrency exchange platform.[60] The four individuals had been sentenced in 2022, and BitMEX was fined US$100 million in 2024 for “violating the Bank Secrecy Act by willfully failing to establish, implement, and maintain an adequate [AML] and [KYC] program”.[61]
In a similar vein, Changpeng Zhao, the founder and CEO of Binance, described as the “world’s largest cryptocurrency exchange”,[62] was pardoned by President Trump on 21 October 2025.[63] Zhao had pled guilty to violating the BSA by failing to maintain an effective AML programme,[64] resulting in a sentence of four months in prison and a US$50 million fine.[65]
Although the scope of prosecutions targeting digital asset platforms has narrowed following DAG Blanche’s memo, recent DOJ enforcement actions demonstrate that the Department’s restraint has clear limits: platforms that knowingly facilitate illicit activity remain squarely in the crosshairs. One prominent example was the international operation to take down Garantex, a cryptocurrency exchange platform, which resulted from coordination between the DOJ and German and Finnish law enforcement authorities.[66] The operation also included indictments against two of Garantex’s administrators: Aleksandr Mira Serda, who is charged with conspiracy to launder money, and Aleksej Besciokov, who is charged with conspiracies to launder money, violate sanctions and operate an unlicensed money transmitting business.[67] The DOJ alleges that Mira Serda and Besciokov knew that criminal organisations were using Garantex as a conduit to launder money and actively worked to conceal the illicit activities, while also continuing to allow US entities to use the platform despite it having been sanctioned by OFAC in April 2022.[68]
The DOJ also targeted Roman Storm, co-founder of the cryptocurrency mixer platform, Tornado Cash, for “willfully conspiring to operate a money transmitting business that moved more than $1 billion in dirty money”.[69] The press release focused on the wilfulness of Storm’s actions, highlighting that Tornado Cash specifically “advertised to customers that it provided untraceable and anonymous financial transactions”, and Storm was “personally aware” that Tornado Cash was being used to launder money from criminal proceeds.[70] Storm was convicted following a jury trial.[71]
Similarly, in November 2025, the CEO, Keonne Rodriguez, and CTO, William Lonergan Hill, of the cryptocurrency mixer Samourai Wallet were sentenced to five and four years in prison, respectively.[72] Over US$237 million was laundered through Samourai, and the evidence suggests that this outcome aligned with Rodriguez’s and Hill’s deliberate intentions.[73] The two designed the application specifically to conceal illicit activity and marketed it as such, including posting to a darknet forum that Samourai could make criminal proceeds “untraceable” and encouraging hackers on Twitter to use Samourai to launder criminal proceeds.[74] Once again, the Department’s press release emphasised that the violations were committed knowingly and wilfully.
Given the DOJ’s focus on prosecuting digital asset platforms that knowingly and wilfully violate AML laws, such platforms should take several proactive steps to mitigate enforcement risk. First, platforms should carefully review the marketing of their services to ensure that no messaging could be construed as insinuating or encouraging criminal usage. Second, platforms should implement robust AML and KYC programmes designed to prevent, detect and report illicit activity. Third, all employees should receive regular, substantive training on the platform’s AML programme and the requirements of the BSA. Finally, the platform should foster a genuine culture of compliance, ensuring that AML obligations are treated as integral to the business rather than as mere formalities.
Bank insiders enabling money laundering schemes
The DOJ has long prioritised holding bank insiders accountable for their role in facilitating money laundering, recognizing that corrupt employees can undermine even the most sophisticated compliance infrastructure from within. This focus has only intensified in recent times. In October 2024, TD Bank NA and its parent company, TD Bank US Holding Company (together, TD Bank), pled guilty to charges of (1) failing to maintain an AML programme that complies with the BSA; (2) failing to file accurate Currency Transaction Reports; and (3) laundering monetary instruments.[75] Between 2019 and 2023, the bank reportedly laundered over US$600 million.[76] The plea agreement carried a criminal penalty of US$1.8 billion, as well as requirements that the bank maintain a more effective AML programme and submit to an independent compliance monitor.[77]
Critically, the institutional guilty plea did not insulate individual TD Bank employees from prosecution. In January 2026, two TD Bank insiders faced separate criminal charges for their respective roles in facilitating money laundering.[78] Wilfredo Aquino, a New York TD Bank assistant store manager, pled guilty to conspiracy to launder monetary instruments.[79] Between 2019 and 2021, Aquino helped the leader of a money laundering network – identified as “David” of “David’s Network” – launder more than US$92 million by processing 1,680 checks for the network leader while deliberately failing to identify David as the conductor on currency transaction reports.[80] Philip Lamparello, Senior Counsel for the Criminal and Special Prosecutions Division of the US Attorney’s Office for the District of New Jersey, emphasised the critical role that bank insiders play in preventing money laundering: “Bank employees are the first line of defense against money laundering, fraud, and other financial crimes. When bank employees ignore their obligations and instead use their positions to commit crimes and line their own pockets, we will not hesitate to hold them accountable.”[81]
Just two weeks after Aquino’s guilty plea, another guilty plea was entered for Oscar Marcel Nunez-Flores, a TD Bank employee in New Jersey.[82] Nunez-Flores pled guilty to conspiracy to launder monetary instruments and for the receipt of bribes by a bank employee.[83] Between 2021 and 2023, Nunez-Flores assisted in moving US$26 million from the United States to Colombia by opening accounts for shell companies and issuing debit cards used for money laundering.[84] The same prosecutor as in Aquino’s case, Lamparello, highlights that money laundering “often depend[s] on insiders”.[85]
TD Bank is not the only financial institution under scrutiny for serving as a conduit for money laundering. In December 2025, Danny Seibel, the former President and CEO of the First National Bank of Lindsay, an Oklahoma-based bank, was indicted for “conspiracy to commit bank fraud, bank fraud, making false entries in the books and records of a financial institution, obstructing the examination of a financial institution and failing to implement an anti-money laundering program”.[86] Seibel served in his role from February 2007 to September 2024, during which time he allegedly modified bank records, provided false records to the Office of the Comptroller of the Currency, failed to implement an AML programme at the bank, and assisted bank customers in evading reporting requirements under the BSA.[87]
In response to these prosecutions, US financial institutions should take concrete steps to mitigate the risk of insider-facilitated money laundering. All employees should be thoroughly and regularly trained on the institution’s AML programme and the corresponding legal framework, including the BSA and the MLCA. Training should be tailored to each employee’s specific role and responsibilities, and it should be conducted on a recurring basis rather than as a one-time onboarding exercise. Beyond training, institutions should foster a genuine culture of compliance that empowers employees to report suspicious activity without fear of retaliation. Banks should also consider implementing automated transaction monitoring systems capable of detecting unusual patterns and flagging potential violations in real time. Finally, regular independent audits of the financial institution’s AML compliance programme can help ensure that the programme remains robust and that there are no gaps that a bank insider could exploit to facilitate money laundering.
Civil enforcement of AML requirements
While the Department has focused its resources on criminal enforcement of AML laws, Treasury has largely moved in the opposite direction, scaling back civil enforcement in several notable respects. In March 2025, the Treasury announced that it would stop enforcing the Corporate Transparency Act against US citizens and domestic reporting companies, including their beneficial owners.[88] US Secretary of the Treasury Scott Bessent explained that this move was “part of President Trump’s bold agenda to unleash American prosperity by reining in burdensome regulations, in particular for small businesses that are the backbone of the American economy”.[89] Further, FinCEN has postponed the effective date of its new rule establishing AML and suspicious activity reporting requirements for investment advisers.[90] Initially supposed to go into effect in January 2026, the rule has been postponed for another two years until 2028.[91] The Federal Deposit Insurance Corporation (FDIC) has also followed suit in relaxing its rules. In June 2025, the FDIC granted an exemption for banks subject to the jurisdiction of the Office of the Comptroller of the Currency, FDIC and the National Credit Union Administration.[92] These banks no longer have to comply with the requirements of the Customer Identification Program Rule for the collection of taxpayer identification numbers and can instead use an alternative collection method to obtain such information from a third party rather than from the customer.[93]
The one area where civil enforcement has not been scaled back is with respect to cartels and TCOs, underscoring the degree to which anti-cartel policy has become the organising principle of the Administration’s entire AML agenda. In June 2025, FinCEN issued unprecedented orders against three financial institutions based in Mexico – CIBanco SA, Institución de Banca Múltiple; Intercam Banco SA, Institución de Banca Múltiple; and Vector Casa de Bolsa, SA de CV – pursuant to the Fentanyl Sanctions Act and the FEND Off Fentanyl Act.[94] FinCEN found that the financial institutions played a role in facilitating money laundering for Mexico-based cartels and payments for chemicals used to produce fentanyl. These orders prohibit certain transmittals of funds with the named financial institutions. Secretary Bessent highlighted Treasury’s role in stopping money laundering and drug trafficking by cartels: “Through the first use of this powerful authority, today’s actions affirm Treasury’s commitment to using all tools at our disposal to counter the threat posed by criminal and terrorist organizations trafficking fentanyl and other narcotics.”[95] While FinCEN has not issued any additional orders under the Fentanyl Sanctions Act and the FEND Off Fentanyl Act since June 2025, it appears that AML enforcement related to cartels and TCOs remains the priority for civil actions as well.
Conclusion
In year two of the second Trump Administration, the DOJ’s AML enforcement priorities have come into sharp focus – and they reveal a Department that has been both strategically selective and operationally aggressive. The Administration has targeted cartels and TCOs from the very outset, establishing this fight as the centrepiece of its AML agenda. Over time, its other priorities have crystallised as well. The DOJ is not only targeting CMLNs for their role in laundering drug trafficking proceeds but is also aggressively pursuing their involvement in defrauding Americans through pig-butchering schemes – an area that has seen significant enforcement activity through the newly established Scam Center Strike Force. Simultaneously, the DOJ has taken a marked departure from the Biden Administration’s approach toward digital asset platforms, signalling that it will not pursue prosecutions absent a specific showing of knowledge and wilfulness on the part of the platform or its operators – though recent cases against Garantex, Tornado Cash and Samourai Wallet demonstrate that this restraint does not extend to platforms that knowingly facilitate crime. On the civil side, the Treasury’s broad scaling back of AML enforcement requirements stands in notable tension with the criminal side’s intensity, with the sole exception being enforcement actions directed at cartel-linked financial institutions.
For companies and financial institutions navigating this enforcement landscape, the takeaway is clear: the current Administration’s AML priorities demand a compliance posture that is both targeted and rigorous. Businesses across all industries must ensure that their AML and KYC programmes are calibrated to detect and prevent transactions that could facilitate the operations of TCOs or CMLNs. Digital asset platforms, in particular, should remain vigilant about activity on their platforms and take proactive measures to identify and address potential money laundering – recognising that evidence of knowledge or wilful blindness could expose the platform and its leadership to criminal liability, notwithstanding the Administration’s otherwise lighter regulatory touch. Financial institutions should invest in robust compliance infrastructure, employee training and internal controls to guard against insider-facilitated money laundering – a risk that, as the TD Bank prosecutions illustrate, can carry consequences reaching into the billions of dollars. As the DOJ’s enforcement actions continue to evolve, the most effective defence will be a compliance programme that is not merely reactive but anticipatory – one that tracks emerging enforcement trends and adapts accordingly.
Endnotes
[1] See 12 U.S.C. §§ 1956-57; 31 U.S.C. § 5322.
[2] Money Laundering: An Overview of 18 U.S.C. § 1956 and Related Federal Criminal Law, Cong. Rsch. Serv. (Jan. 29, 2026), https://www.congress.gov/crs_external_products/RL/PDF/RL33315/RL33315.18.pdf.
[3] Head of the Criminal Division, Matthew R. Galeotti Delivers Remarks at SIFMA’s Anti-Money Laundering and Financial Crimes Conference, U.S. Dep’t of Just., (May 12, 2025), https://www.justice.gov/opa/speech/head-criminal-division-matthew-r-galeotti-delivers-remarks-sifmas-anti-money-laundering.
[4] Memorandum from Att’y Gen. Pam Bondi to All U.S. Dep’t of Just. Emp.’s (Feb. 5, 2025) https://www.justice.gov/ag/media/1388546/dl?inline.
[6] The KleptoCapture Task Force was designed to enforce sanctions and other trade controls. Press Release, U.S. Dep’t of Just., Attorney General Merrick B. Garland Announces Launch of Task Force KleptoCapture (Mar. 2, 2022), https://www.justice.gov/archives/opa/pr/attorney-general-merrick-b-garland-announces-launch-task-force-kleptocapture.
[7] Memorandum from Att’y Gen. Pam Bondi, supra note 5, at 4.
[8] U.S. Dep’t of Just., Operation Take Back America, https://www.justice.gov/usao-mdpa/operation-take-back-america.
[9] Memorandum from Deputy Att’y Gen. Todd Blanche to All U.S. Dep’t of Just. Emp.’s (Mar. 6, 2025) https://www.justice.gov/dag/media/1393746/dl?inline.
[10] Press Release, U.S. Dep’t of Just., Florida Man Convicted of Leading $300 Million Money Laundering Operation for Transnational Criminal Organizations (Dec. 12, 2025), https://www.justice.gov/usao-edny/pr/florida-man-convicted-leading-300-million-money-laundering-operation-transnational.
[16] Press Release, U.S. Dep’t of Just., Mexican Cartel Leader Sentenced to Over 11 Years in Prison for International Money Laundering (Dec. 18, 2025), https://www.justice.gov/opa/pr/mexican-cartel-leader-sentenced-over-11-years-prison-international-money-laundering.
[21] Press Release, U.S. Dep’t of Just., Ohio Siblings Sentenced for Laundering $784,045 in Drug Proceeds (Aug. 21, 2025), https://www.justice.gov/opa/pr/ohio-siblings-sentenced-laundering-784045-drug-proceeds.
[24] Press Release, U.S. Dep’t of Treas., FinCEN Issues Modified Southwest Border Geographic Targeting Order (Sept. 8, 2025), https://www.fincen.gov/news/news-releases/fincen-issues-modified-southwest-border-geographic-targeting-order.
[26] Memorandum from Matthew R. Galeotti to All U.S. Dep’t of Just. Crim. Div. Pers. (May 12, 2025) https://www.justice.gov/criminal/media/1400046/dl?inline.
[27] FinCEN, FinCEN Advisory on the Use of Chinese Money Laundering Networks by Mexico-Based Transnational Criminal Organizations to Launder Illicit Proceeds (Aug. 28, 2025), http://fincen.gov/system/files/2025-08/FinCEN-Advisory-CMLN-508.pdf.
[29] Press Release, U.S. Dep’t of Just., Two Members of a Transnational Money Laundering Organization Sentenced for Laundering Millions of Dollars in Drug Proceeds (Apr. 11, 2025) https://www.justice.gov/opa/pr/two-members-transnational-money-laundering-organization-sentenced-laundering-millions.
[33] Press Release, U.S. Dep’t of Just., Key Member of Chinese Money Laundering Network Charged with Laundering Tens of Millions of Dollars in Drug Proceeds (Jan. 8, 2026), https://www.justice.gov/opa/pr/key-member-chinese-money-laundering-network-charged-laundering-tens-millions-dollars-drug.
[37] Press Release, U.S. Dep’t of Just., New Scam Center Strike Force Battles Southeast Asian Crypto Investment Fraud Targeting Americans (Nov. 12, 2025), https://www.justice.gov/usao-dc/pr/new-scam-center-strike-force-battles-southeast-asian-crypto-investment-fraud-targeting.
[43] Press Release, U.S. Dep’t of Just., Chairman of Prince Group Indicted for Operating Cambodian Forced Labor Scam Compounds Engaged in Cryptocurrency Fraud Schemes (Oct. 14, 2025), https://www.justice.gov/opa/pr/chairman-prince-group-indicted-operating-cambodian-forced-labor-scam-compounds-engaged.
[51] Press Release, U.S. Dep’t of Just., Scam Center Strike Force Announces Seizure of Fake Cryptocurrency Investment Domain Used by Tai Chang Scam Compound in Burma (Dec. 2, 2025), https://www.justice.gov/usao-dc/pr/scam-center-strike-force-announces-seizure-fake-cryptocurrency-investment-domain-used.
[55] See also Executive Order “Strengthening American Leadership in Digital Financial Technology” (Jan. 23, 2025), https://www.whitehouse.gov/presidential-actions/2025/01/strengthening-american-leadership-in-digital-financial-technology/.
[56] Memorandum from Deputy Att’y Gen. Todd Blanche to All U.S. Dep’t of Just. Emp.’s (Apr. 7, 2025) https://www.justice.gov/dag/media/1395781/dl?inline.
[58] Matthew R. Galeotti, Acting Assistant Att’y Gen., Remarks at the American Innovation Project Summit (Aug. 21, 2025), https://www.justice.gov/opa/speech/acting-assistant-attorney-general-matthew-r-galeotti-delivers-remarks-american.
[59] Presidential Pardon of Arthur Hayes (Mar. 27, 2025), https://www.justice.gov/pardon/media/1394991/dl?inline; Presidential Pardon of Benjamin Delo (Mar. 27, 2025), https://www.justice.gov/pardon/media/1394981/dl?inline; Presidential Pardon of Samuel Reed (Mar. 27, 2025), https://www.justice.gov/pardon/media/1395006/dl?inline; Presidential Pardon of Gregory Dwyer (Mar. 27, 2025), https://www.justice.gov/pardon/media/1394986/dl?inline.
[60] Press Release, U.S. Dep’t of Just., Global Cryptocurrency Exchange BitMEX Fined $100 Million For Violating Bank Secrecy Act (Jan. 15, 2025), https://www.justice.gov/usao-sdny/pr/global-cryptocurrency-exchange-bitmex-fined-100-million-violating-bank-secrecy-act.
[62] Press Release, U.S. Dep’t of Just., Binance and CEO Plead Guilty to Federal Charges in $4B Resolution (Nov. 21, 2023), https://www.justice.gov/archives/opa/pr/binance-and-ceo-plead-guilty-federal-charges-4b-resolution.
[63] Presidential Pardon of Changpeng Zhao (Oct. 21, 2025), https://www.justice.gov/pardon/media/1416576/dl?inline.
[64] Binance and CEO Plead Guilty to Federal Charges in $4B Resolution, supra note 63.
[65] U.S. Dep’t of Just., Clemency Grants by President Donald J. Trump (2025-Present), https://www.justice.gov/pardon/clemency-grants-president-donald-j-trump-2025-present.
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[69] Press Release, U.S. Dep’t of Just., Founder Of Tornado Cash Crypto Mixing Service Convicted Of Knowingly Transmitting Criminal Proceeds (Aug. 6, 2025), https://www.justice.gov/usao-sdny/pr/founder-tornado-cash-crypto-mixing-service-convicted-knowingly-transmitting-criminal.
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[77] U.S. Dep’t of Just., United States of America v. TD Bank, N.A., https://www.justice.gov/criminal/case/united-states-america-v-td-bank-na.
[78] Press Release, U.S. Dep’t of Just., TD Bank Insider Pleads Guilty to Facilitating Money Laundering (Jan. 6, 2026), https://www.justice.gov/opa/pr/td-bank-insider-pleads-guilty-facilitating-money-laundering; Press Release, U.S. Dep’t of Just., TD Bank Insider Pleads Guilty to Facilitating Colombian ATM Money Laundering Scheme (Jan. 21, 2026), https://www.justice.gov/opa/pr/td-bank-insider-pleads-guilty-facilitating-colombian-atm-money-laundering-scheme.
[79] TD Bank Insider Pleads Guilty to Facilitating Money Laundering, supra note 79.
[82] TD Bank Insider Pleads Guilty to Facilitating Colombian ATM Money Laundering Scheme, supra note 79.
[86] Press Release, U.S. Dep’t of Just., Former President of Failed Oklahoma Bank Indicted for Bank Fraud (Dec. 4, 2025), https://www.justice.gov/opa/pr/former-president-failed-oklahoma-bank-indicted-bank.
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