U.S. Department of the Treasury: 2024 National Money Laundering Risk Assessment (NMLRA)

This report identifies the most significant money laundering threats, vulnerabilities, and risks the United States faces. With a gross domestic product (GDP) of 25 trillion dollars, the United States is the world’s largest economy and is particularly susceptible to the laundering of illicit proceeds. This risk is also due to the value, stability, and the centrality of the U.S. dollar in the global economy’s payment infrastructure.

Like 2022, this year’s risk assessment identifies the most significant money laundering crimes in the United States are linked to fraud, drug trafficking, cybercrime, human trafficking, human smuggling, and corruption. In addition, this report includes a “special focus” on risks that were not identified or fully addressed in previous risk assessments.

Criminals and transnational criminal organizations (TCOs) continue to use cash to launder illicit proceeds because it provides anonymity, stability, and is widely accepted. While bulk cash smuggling and the use of cash-intensive businesses are historically favored laundering methods for many DTOs, criminals have expanded the way they transport currency, including using new cities as cash consolidation points to convert bills more expeditiously. They also charter private aircraft to smuggle cash via less monitored routes.

While the use of virtual assets for money laundering remains far below that of fiat currency, this assessment provides a comprehensive update on existing and evolving trends in AML/CFT risks associated with virtual assets, including inconsistent compliance with domestic laws and international AML/CFT obligations, obfuscation tools and methods, mixing, disintermediation, and other aspects of purported decentralized finance (DeFi).

This Report was prepared pursuant to Sections 261 and Section 262 of the Countering America’s Adversaries Through Sanctions Act (PL 115-44)as amended by Section 6506 of the FY22 National Defense Authorization Act (NDAA) (P.L. 117-81). The 2024 NMLRA primarily relies on open-source reporting from the Department of Justice (DOJ), the use of publicly available court documentation, and consultations with law enforcement agencies (LEAs).3 The NMLRA also utilizes information from Bank Secrecy Act (BSA) reporting, such as strategic analysis on suspicious activity reports (SARs) conducted by the Financial Crimes Enforcement Network (FinCEN) as well as various types of enforcement actions taken by U.S. regulatory agencies. (See Annex on Methodology for further information.)

View U.S. Department of the Treasury: 2024 National Money Laundering Risk Assessment (NMLRA)

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