US Treasury Releases 2024 National Risk Assessments on Money Laundering, Terrorist Financing, and Proliferation Financing

The U.S. Department of the Treasury has published its 2024 National Risk Assessments on Money Laundering, Terrorist Financing, and Proliferation Financing [^1^]. This report highlights the most significant illicit finance threats and vulnerabilities faced by the United States in the evolving global risk environment.

Key Findings

Money Laundering

• Criminals use both traditional and novel money laundering techniques to move and conceal illicit proceeds.

• The largest sources of illicit proceeds laundered in or through the U.S. are:

  • Fraud
  • Drug trafficking
  • Cybercrime
  • Human trafficking and human smuggling
  • Corruption

• Persistent and emerging money laundering risks include:

  • Misuse of legal entities
  • Lack of transparency in real estate transactions
  • Gaps in anti-money laundering/counter-financing of terrorism (AML/CFT) coverage for certain sectors
  • Complicit merchants and professionals
  • Weaknesses in compliance or supervision at some financial institutions

Terrorist Financing

• The U.S. faces a wide range of terrorist financing threats and actors, both foreign and domestic.

• Hamas continues to exploit the international financial system:

  • Soliciting funds from unwitting donors
  • Utilizing virtual assets

• Domestic violent extremist movements have gained momentum:

  • Challenging law enforcement
  • Continuing to pose threats to U.S. security

Proliferation Financing

• Russia and the Democratic People’s Republic of Korea (DPRK) pose heightened risks for proliferation financing.

• Russia’s illegal war in Ukraine:

  • Expanding efforts to acquire U.S.-origin goods with military applications
  • Utilizing obfuscation techniques

• The DPRK increasingly exploits the digital economy:

  • Engaging in hacking
  • Fraudulent employment
  • Money laundering

Collaboration and Improvements

• The U.S. Department of the Treasury’s Office of Terrorist Financing and Financial Crimes spearheaded the assessment process.

• Collaboration with offices and bureaus across the Department, federal functional regulators, law enforcement agencies, intelligence, and diplomatic communities.

• Recent improvements to the AML/CFT regime include:

  • New beneficial ownership reporting requirement (effective from January 1, 2024)
  • Forthcoming proposed rules targeting vulnerabilities in the residential real estate sector
  • Proposed rules for certain investment advisers

Under Secretary of the Treasury for Terrorism and Financial Intelligence, Brian E. Nelson, stated:

“Illicit finance is a common thread across our nation’s biggest national security threats. The 2024 National Risk Assessments allow us to analyze the global risk environment and protect the U.S. and international financial systems from abuse by illicit actors.” [^1^] US Department of the Treasury (2024). 2024 National Risk Assessments on Money Laundering, Terrorist Financing, and Proliferation Financing. Washington, DC.