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Thompson Hine LLP, a full-service business law firm with approximately 400 lawyers in 11 offices, was ranked number 1 in the category “Most innovative North American law firms: New working models” by The Financial Times and was 1 of 7 firms shortlisted for The American Lawyer’s inaugural Legal Services Innovation Award. The firm has been recognized by the National Law Journal as a Legal Technology Trailblazer and featured by Bloomberg for its innovative service delivery models, which drive accuracy and predictability. The firm’s commitment to innovation is embodied in Thompson Hine SmartPaTHTM – a smarter way to work – predictable, efficient and aligned with client goals. For more information, please visit ThompsonHine.com and ThompsonHine.com/SmartPaTH.

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<h2 class="wp-block-heading">Continuing U.S. Enforcement Targeting of Cartels and Related Support</h2>
<p>On August 28, 2025, the Financial Crimes Enforcement Network (FinCEN) issued Advisory FIN-2025-A003 and an accompanying Financial Trend Analysis to alert U.S. financial institutions of the significant and escalating threat posed by Chinese money laundering networks (CMLNs).</p>
<p>The first component, Advisory FIN-2025-A003, urges vigilance in detecting and reporting CMLN activity, outlines key typologies, and provides detailed red-flag indicators. The second, a Financial Trend Analysis, distills five years of Bank Secrecy Act data to illustrate the scope, channels, and sectors most vulnerable to CMLN exploitation.</p>
<h2 class="wp-block-heading">Key Notes</h2>
<ul class="wp-block-list">
<li>The U.S. government continues to enhance a multi-pronged enforcement approach targeting cartels and related money laundering.</li>
<li>FinCEN is increasing its focus on money laundering networks involving Chinese companies supporting fentanyl production and drug cartels. Sanctions of foreign banks by FinCEN may increase.</li>
<li>Companies should review international banking arrangements for risk that banks may be sanctioned by FinCEN.</li>
<li>Companies should ensure that their third-party due diligence adequately addresses these money laundering and cartel risks.</li>
</ul>
<p><strong>View the entire client update in <a href="https://www.thompsonhine.com/insights/fincen-issues-advisory-and-financial-trend-analysis-on-chinese-money-laundering-networks/">HTML</a> or <a href="https://admin.thompsonhine.com/wp-content/uploads/2025/09/FinCEN-Issues-Advisory-and-Financial-Trend-Analysis-on-Chinese-Money-Laundering-Networks.pdf" target="_blank" rel="noreferrer noopener">PDF</a> format.</strong></p>

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Francesca M.S. Guerrero

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Aaron C. Mandelbaum

International Trade

Trade Crimes Defense

FinCEN Issues Advisory and Financial Trend Analysis on Chinese Money Laundering Networks