FBI Sees Significant Risk That Private Funds Are Exploited for Money Laundering

Money laundering and terrorist financing remain pressing concerns of both law enforcement and regulatory agencies. A recent collection of leaked law enforcement documents, referred to as “BlueLeaks,” includes an unclassified internal memorandum (Bulletin) which was prepared by the FBI on the potential use of private investment funds for money laundering. According to the Bulletin, the FBI is “highly confident” that private funds are being – and will continue to be – used for money laundering. This article discusses the FBI’s key assumptions and conclusions. For more on money laundering, see “Lessons Private Fund Managers Can Learn From U.S. Bancorp’s Settlement of AML Violations” (Apr. 26, 2018); and “FCA Fines Deutsche Bank £163 Million for Lax AML Controls, Warns Other Firms to Review AML Procedures” (Feb. 9, 2017).

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