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Third-Party Money Launderers
Each year, the U.S. government secures more than 1,200 money-laundering convictions. Now, the Federal Bureau of Investigation (FBI), at least, is setting its sights with renewed vigor on those who help criminal organizations and terrorists conceal billions in illicit funds. Last October, the FBI announced that it would prioritize money-laundering investigations of “third-party facilitators,” such as attorneys, accountants, investment managers, trust companies and real estate professionals. Specialized FBI Unit Focuses on Disrupting Professional Money Launderers (Oct. 24, 2016). This comes amidst growing international pressure for countries to close regulatory gaps in anti-money laundering (AML) and counter-terrorist financing rules. The Financial Action Task Force (FATF), for example, recently urged the United States to improve its regulation of designated non-financial businesses and professions, as well as of shell companies. FATF, Anti-Money Laundering and Counter-Terrorist Financing Measures, United States (Dec. 1, 2016).
FATF's report and the FBI's initiative should serve as a warning sign: The authorities have diminishing patience for professionals and other third-party facilitators who act as conduits for money laundering and financial crime, more generally. Recent prosecutions in this area illustrate some of the common typologies by which such organizations and individuals can use their positions and services to conceal and launder illicit funds.
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