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2/7/2024

Treasury Publishes 2024 National Risk Assessments for Money Laundering, Terrorist Financing, and Proliferation Financin…

Treasury Publishes 2024 National Risk Assessments for Money
Laundering, Terrorist Financing, and Proliferation Financing
February 7, 2024

Reports Confirm and Update Key Illicit Finance Concerns in Response to Evolving Threat and
Risk Environment

WASHINGTON – Today, the U.S. Department of the Treasury published the 2024 National Risk
Assessments on Money Laundering, Terrorist Financing, and Proliferation Financing. These
reports highlight the most significant illicit finance threats, vulnerabilities, and risks facing the
United States.
The reports detail recent, significant updates to the U.S. anti-money laundering /counterfinancing of terrorism framework and explain changes to the illicit finance risk environment.
These include the ongoing fentanyl crisis, foreign and domestic terrorist attacks and related
financing, increased potency of ransomware attacks, the growth of professional money
laundering, and continued digitization of payments and financial services. These assessments
also address how significant threats to global peace and security—such as Russiaʼs ongoing
illegal, unprovoked, and unjustified war in Ukraine and Hamasʼs October 7, 2023 terrorist
attacks in Israel—have shaped the illicit finance risk environment in the United States.
Todayʼs publications are the fourth iterations of the money laundering and terrorist financing
risk assessment, and the third update of the proliferation financing risk assessment, in less
than a decade. The public and private sectors can use these updated risk assessments to
better understand the current illicit finance environment and inform their own risk mitigation
strategies.
“Whether itʼs terrorism, drug tra icking, Russian aggression, or corruption, illicit finance is the
common thread across our nationʼs biggest national security threats,” said Under Secretary of
the Treasury for Terrorism and Financial Intelligence Brian E. Nelson. “Treasury, through our
National Risk Assessments, is at the cutting edge of analyzing the global risk environment to
protect the U.S. and international financial systems from abuse by illicit actors. We urge both
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Treasury Publishes 2024 National Risk Assessments for Money Laundering, Terrorist Financing, and Proliferation Financin…

the public and private sectors to engage with these reports, as well as our forthcoming
National Strategy for Combatting Terrorist and Other Illicit Finance.”

KEY F INDINGS:
Money Laundering: Criminals use both traditional and novel money laundering
techniques, depending on availability and convenience, to move and conceal illicit
proceeds and promote criminal activity that harms Americans. The crimes that generate
the largest amount of illicit proceeds laundered in or through the United States remain
fraud, drug tra icking, cybercrime, human tra icking and human smuggling, and
corruption. The United States continues to face both persistent and emerging money
laundering risks related to: (1) the misuse of legal entities; (2) the lack of transparency in
certain real estate transactions; (3) the lack of comprehensive AML/CFT coverage for
certain sectors, particularly investment advisers; (4) complicit merchants and
professionals that misuse their positions or businesses; and (5) pockets of weaknesses in
compliance or supervision at some regulated U.S. financial institutions.

Terrorist Financing: The United States continues to face a wide range of terrorist
financing threats and actors, both foreign and domestic. Consistent with the 2022 risk
assessment, the most common financial connections between individuals in the United
States and foreign terrorist groups entail individuals directly soliciting funds for or
attempting to send funds to foreign terrorist groups utilizing cash, registered money
services businesses, or in some cases, virtual assets. The 2024 report also discusses
Hamas and the ways they exploit the international financial system, including through
solicitation of funds from witting and unwitting donors worldwide. Additionally, domestic
violent extremist movements have proliferated in recent years, posing an elevated threat
to the United States and continued challenges for law enforcement.

Proliferation Financing: Russia and the Democratic Peopleʼs Republic of Korea (DPRK)
presented heightened risk since the 2022 assessment. To support its unlawful war in
Ukraine, Russia has expanded e orts to illegally acquire U.S.-origin goods with military
applications using a variety of obfuscation techniques, such as the use of front companies
and transshipment points around the world. Networks linked to the DPRK increasingly

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exploit the digital economy, including through hacking of virtual asset service providers
and the overseas deployment of fraudulent information technology workers.
Treasuryʼs O ice of Terrorist Financing and Financial Crimes led the assessment process and
coordinated closely with o ices and bureaus across the Department, relevant law
enforcement and regulatory agencies, sta of the federal functional regulators, and across
the intelligence and diplomatic communities.
In the coming weeks, Treasury will release the 2024 National Strategy for Combatting
Terrorist and Other Illicit Finance, a strategic plan directly informed by the analysis contained
in the risk assessments. In the strategy, Treasury will share recommendations for addressing
the highlighted issues. This valuable feedback has aided Treasury in assessing and addressing
illicit finance risk identified in prior iterations of the strategy to support improvements to the
AML/CFT regime, including the launching of the new beneficial ownership reporting
requirement that went into e ect on January 1, 2024, and informing forthcoming proposed
rules to address illicit finance vulnerabilities in the residential real estate sector and for
certain investment advisers.

READ MORE:
The 2024 National Money Laundering Risk Assessment
The 2024 National Terrorist Financing Risk Assessment
The 2024 National Proliferation Financing Risk Assessment
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