FINCEN'S BELATED AML/CFT ACTION AGAINST REGISTERED INVESTMENT ADVISERS WILL MOVE LAUNDRYMAN ENGAGED IN INVESTMENTS FOR INTEGRATION SEAMLESSLY INTO TBML

After two decades of delay and procrastination, the current leadership at FinCEN has given notice that tomorrow (15 Feb 24), it will engage in proposed AML/CFT rulemaking against Registered Investment Advisers and Exempt Reporting Advisers. Sanctioned Russian oligarchs aren't the only ones artfully making investments within the US, using those loopholes, laundrymen for drug kingpins often engage in the Integration phase of their operations in that manner, things are about to change, and compliance officers need be sensitive to the fact that money launderers proactively, and effortlessly, change financial horses in midstream.

What this means is that offshore laundrymen, who will no longer feel safe and secure investing clean drug capital through investment advisers, given the new AML/CFT responsibilities that are about to be forced upon them, will resort to one of the other tried-and-true ways to make domestic investments in American capitalism: bringing the money in through Trade-Based Money Laundering (TBML), paying minimal taxes on it, and dropping those squeaky clean profits directly on income-producing investments. They will avoid their former investment advisers like the plague, as those SAR reporting requirements which will become commonplace among newly restricted advisers could implicate them, or their clients.

We do not know precisely what percentage of the funds placed in the hands of investment advisers would fail Source of Funds & Source of Wealth tests, but one should expect substantial future narco-profits to end up being moved onshore via Trade-Based Money Laundering, once the new Rule becomes effective. Watch for it, ladies & gentlemen.