Illicit financial activity involving what the U.S. government terms Chinese Money Laundering Organizations or Networks (CMLOs or CMLNs) is an issue that has increasingly attracted congressional attention. Although the money laundering methods employed by CMLNs are not necessarily unique, compared to the activity of other money laundering organizations, CMLNs have emerged as a U.S. foreign policy concern due to their (1) prominent role in evading currency controls imposed by the government of the People’s Republic of China (PRC or China); and (2) ability to launder vast sums of illicit proceeds for Mexican transnational criminal organizations (TCOs) implicated in fentanyl production and trafficking. U.S. government reports appear to use the terms CMLOs or CMLNs to refer to third-party money laundering networks with links to the PRC. These networks may operate, at least in part, in the PRC, among other countries. They may also involve PRC citizens or other non-PRC nationals with kinship or cultural ties to the PRC. Such laundering networks leverage PRC ties to specialize in providing informal and black-market financial services, such as currency exchange brokerage, to a variety of actors, including wealthy PRC nationals seeking access to foreign currency beyond the PRC’s currency control limits. The terms CMLO and CMLN do not appear to imply a relationship between the money launderers or laundering activity and the government of China or its ruling party, the Communist Party of China (CPC, also known as the Chinese Communist Party, or CCP).
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