The U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) published its 2024 National Money Laundering and Terrorist Financing Risk Assessments on February 7, 2024, identifying key vulnerabilities across sectors, regions, and transaction types. This periodic risk assessment is a vital guidepost for AML professionals, offering strategic direction for monitoring and controls in the year ahead.

Key findings emphasized the misuse of digital assets, the role of gatekeepers (such as lawyers and trust service providers), real estate laundering, and drug trafficking proceeds—especially from fentanyl—flowing through trade-based channels. The Treasury also highlighted concerns around beneficial ownership opacity, particularly in state-registered shell companies, and the need to close gaps in non-bank financial intermediaries.

The report recommends greater public-private collaboration, enhanced data analytics in transaction monitoring, and the implementation of robust customer due diligence (CDD) regimes across all financial services segments. Notably, it also references emerging threats in decentralized finance (DeFi), warning institutions to enhance surveillance of peer-to-peer platforms and mixer usage.

For financial institutions, the 2024 assessments offer actionable insights to refine AML programs. Risk teams should conduct internal reviews aligned to these national priorities, update typologies, and refine monitoring rules. Institutions operating in high-risk geographies or dealing with high-risk customers must strengthen internal oversight, training, and quality assurance protocols.

Source: Treasury Publishes 2024 National Risk Assessments for Money Laundering, Terrorist Financing, and Proliferation Financing
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