February 8, 2024

US issues updated money laundering, terrorist financing, and proliferation financing risk assessments

On February 7, 2024, the US Department of the Treasury published the 2024 National Risk Assessments on Money Laundering, Terrorist Financing, and Proliferation Financing to identify the most significant threats, vulnerabilities, and risks faced in the United States.  The reports cover recent updates made to the US anti-money laundering/counter-financing terrorism (“AML/CFT”) framework and discuss how recent events – such as the fentanyl crisis, increased ransomware attacks, Russia’s war in Ukraine, and Hamas’s terrorist attacks in Israel – have changed the illicit finance risk environment in the United States.  According to Under Secretary of the Treasury for Terrorism and Financial Intelligence Brian Nelson, the reports are intended to “protect the US and international financial systems from abuse by illicit actors.”  He also urged public and private sectors to engage these reports and the National Strategy for Combatting Terrorist and Other Illicit Finance, a strategic plan expected to be released in the coming weeks, in order to better understand the current illicit finance environment and inform their own risk mitigation strategies.

The Department highlighted several key findings in each report.  In the area of money laundering, the Department confirmed that crimes of fraud, drug trafficking, cybercrime, human trafficking and smuggling, and corruption continue to generate the largest amount of laundering proceeds in or through the United States.  In the area of terrorist financing, the Department indicated that the most common financial connection between US individuals and foreign terrorist groups continues to be individuals who directly solicit funds for or attempt to send funds to these groups by utilizing cash, registered money services businesses, or in some cases, virtual assets.  With regards to proliferation financing, the Department stated that the risks posed by Russia and the Democratic People’s Republic of Korea (“DPRK”) have increased since the 2022 assessment, and networks linked to the DPRK are increasingly exploiting the digital economy.

US Department of Treasury Press Release | 2024 National Money Laundering Risk Assessment | 2024 National Terrorist Financing Risk Assessment | 2024 National Proliferation Financing Risk Assessment