New U.S. Law Will Dramatically Impact Scammers and Terrorists

The United States Just Changed How Financial Crime Is Defined

The Game Is About To Change

This new law marks a turning point in how the United States confronts financial crime by shifting enforcement from isolated transactions to the systems that move and hide money. While it targets terrorism, it also directly impacts scams and fraud. It directly targets the infrastructure that enables scams, organized crime, and cross-border fraud, closing gaps that criminals have exploited for years. By focusing on patterns, networks, and money movement, it gives law enforcement the tools needed to disrupt scams at scale rather than reacting after victims are harmed.

New U.S. Senate Bill S.3643 – 118th Congress

In January 2024, the U.S. Congress quietly introduced one of the most consequential financial crime reforms in decades. The U.S. Congress introduced the Combating Money Laundering, Terrorist Financing, and Counterfeiting Act of 2024, a bipartisan measure introduced by Chuck Grassley and Amy Klobuchar. While publicly framed around terrorism and national security, the law reaches far beyond those boundaries.

This legislation fundamentally rewrites how money laundering is prosecuted in the United States. Rather than focusing primarily on “dirty money” after a crime has occurred, the new law targets money movement itself. It shifts enforcement away from isolated transactions and toward patterns, networks, and systems.

That change has major implications for transnational organized crime, including global scam operations that rely on fragmented payments, informal remittance channels, crypto intermediaries, and synthetic identities to move and conceal proceeds.

For years, large-scale scam syndicates have exploited gaps between outdated statutes and modern financial behavior. They structured transactions below reporting thresholds, relied on unlicensed money services, used crypto kiosks and peer-to-peer platforms, and leveraged informal value-transfer systems to move funds across borders. Much of this activity existed in a legal gray zone where intent was difficult to prove, and enforcement tools were limited.

That Gray Zone has Now Narrowed Dramatically

The new law allows prosecutors to aggregate multiple small transactions into a single laundering offense when they are linked by timing, purpose, or participants. It explicitly brings informal value-transfer systems, digital assets, and substitute currencies into the legal definition of money laundering. It makes operating an unlicensed or non-compliant money service business a standalone felony, even without proof that the operator understood the rules. It restores and expands wiretap authority for financial crime investigations. It elevates remittances to a national-security concern requiring coordinated analysis across Treasury, regulators, and law enforcement. It also treats counterfeiting tools and fake documents as core financial crime enablers, recognizing their role in mule networks, shell companies, and synthetic KYC schemes.

Taken together, these provisions signal a strategic shift. The United States is no longer waiting for illicit money to surface inside the banking system before acting. Instead, it is criminalizing the infrastructure and behaviors that move money, regardless of the form that money takes or the jurisdiction it crosses.

For global scam networks, this is a direct challenge to their operating model. Romance scams, investment fraud, business email compromise, pig-butchering schemes, and other transnational frauds depend on distributed payment pathways and deniability at each step. By targeting aggregation, informal systems, unlicensed intermediaries, and identity fabrication, the law attacks the connective tissue that allows these crimes to scale.

This will serve as an introduction to what the new law does, why it matters, and how it reshapes the enforcement landscape. What follows is a deeper analysis of the statute’s key provisions and their likely impact on transnational organized crime, financial institutions, compliance professionals, and the future of scam enforcement.

The rules of money laundering enforcement will change, and the consequences will extend far beyond terrorism cases and into the core financial mechanics of global fraud.

Why the U.S. Secret Service Now Sits at the Center of Financial-Crime Enforcement

One of the most significant but least publicly discussed elements of the new law is the expanded statutory role of the U.S. Secret Service (part of DHS). While commonly associated with protective duties, the Secret Service was originally created to combat financial crime, and this legislation deliberately re-centers that mission.

The United States Secret Service (.gov) was originally created on July 5, 1865, as the “Secret Service Division” within the Department of the Treasury. Established to combat rampant currency counterfeiting after the Civil War, it was often referred to as the Treasury’s “secret service” before becoming an official agency.

The law explicitly strengthens the Secret Service’s authority to investigate money laundering, illegal money service businesses, counterfeiting, bulk cash smuggling, and related financial crime networks. This is not a symbolic change. It reflects a recognition that modern financial crime, including large-scale scam operations, now functions as a networked economic system, not a series of isolated fraud incidents.

The Secret Service is uniquely positioned for this role. Unlike agencies that primarily focus on victims or predicate offenses, the Secret Service specializes in tracing money movement, dismantling payment infrastructure, and targeting the operational backbone of criminal enterprises. This law expands its ability to pursue those objectives earlier and more aggressively.

A critical component of that expansion is the restoration and broadening of wiretap authority tied specifically to financial crimes. Scam syndicates and transnational laundering networks rely heavily on encrypted messaging platforms, layered intermediaries, and compartmentalized communications. By expanding surveillance authority connected to illegal money services and laundering conspiracies, the law allows investigators to penetrate coordination layers that were previously difficult to reach under narrower statutes.

The law also reinforces the Secret Service’s role in addressing counterfeiting as a financial crime enabler. Fake documents, synthetic identities, and counterfeit credentials are not peripheral tools. They are central to how scam networks establish mule accounts, open shell companies, bypass KYC controls, and move funds across borders. By treating possession of counterfeiting tools as a serious felony connected to laundering activity, the statute aligns enforcement authority with real-world scam operations.

For transnational scam networks, this matters because the Secret Service does not simply pursue individuals. It targets systems. Its investigations often focus on payment processors, crypto on-ramps, unlicensed remitters, mule recruitment pipelines, and document-forgery supply chains. The new law expands the legal foundation for those investigations and lowers the barriers to acting before proceeds fully disappear offshore.

This expanded role also signals a broader strategic shift within U.S. enforcement. Financial crime is no longer viewed as a downstream consequence of scams, trafficking, or cybercrime. It is treated as the primary attack surface. By empowering the Secret Service to lead complex, multi-jurisdictional financial investigations, Congress is emphasizing disruption over reaction.

In practical terms, this means scam enforcement will increasingly focus on collapsing the economic infrastructure that allows fraud to scale. Payment corridors, informal value-transfer systems, crypto kiosks, shadow MSBs, and identity-fabrication networks now fall squarely within a strengthened investigative mandate.

The expansion of the Secret Service’s authority under this law is not about increasing penalties alone. It is about changing who leads, how cases are built, and where enforcement pressure is applied. For global scam organizations that depend on fragmented money movement and anonymity, this represents a substantial and structural threat.

How the Expanded Secret Service Role Shifts the FBI’s Focus in Financial-Crime and Scam Enforcement

The expanded authority granted to the U.S. Secret Service under the new law does not sideline the Federal Bureau of Investigation. Instead, it rebalances federal enforcement roles in a way that reflects how modern scam networks actually operate.

At a high level, the shift separates financial-infrastructure disruption from predicate crime and victim-impact investigation, allowing each agency to concentrate on what it does best.

From Case-Centric to Infrastructure-Centric Enforcement

Historically, the FBI has led most large scam and fraud cases because scams were framed primarily as criminal deception offenses. Investigations focused on identifying perpetrators, documenting victim losses, establishing intent, and proving individual criminal acts.

The new law reframes scams as financial systems crimes as much as deception crimes. That reclassification naturally elevates the Secret Service, whose core expertise lies in tracing money movement, dismantling payment channels, and attacking money laundering infrastructure.

As a result:

• The Secret Service increasingly leads investigations targeting unlicensed MSBs, shadow payment processors, crypto on-ramps, mule networks, and counterfeit-enabled identity systems.
• The FBI concentrates more heavily on the human and organizational dimensions of scams: recruitment, coercion, trafficking, cyber intrusion, extortion, conspiracy, and victimization patterns.

This is not duplication. It is functional specialization.

FBI Focus Shifts Upstream Toward Criminal Ecosystems

As the Secret Service applies pressure on the money layer, the FBI’s role shifts upstream toward:

• Identifying scam-compound operators, recruiters, and controllers.
• Investigating forced labor, human trafficking, and coercion within scam operations.
• Pursuing cyber intrusion, business email compromise, ransomware, and platform abuse.
• Building conspiracy cases that link fraud proceeds to broader organized-crime structures.

The FBI remains the primary agency for:

• Victim identification and victim-impact evidence.
• Intelligence on criminal hierarchies and leadership.
• International criminal coordination beyond pure financial flows.

In effect, the FBI focuses more on who is running the crime, while the Secret Service focuses more on how the crime is financed and scaled.

Reduced FBI Burden on Technical AML Prosecution

Before this law, FBI cases often stalled at the laundering stage because:

• Transactions were individually below thresholds.
• Informal remittance systems fell outside clear statutory definitions.
• Intent and knowledge were difficult to prove.

By making aggregation easier, criminalizing unlicensed MSBs outright, and expanding wiretap authority for financial crimes, the new statute reduces the FBI’s burden of proving complex AML elements inside fraud cases.

That allows the FBI to:

• Move faster on arrests and indictments.
• Focus resources on violent, coercive, and cyber-enabled aspects of scam networks.
• Rely on Secret Service-led financial cases to neutralize the profit engine in parallel.

Parallel Investigations Instead of Sequential Ones

Previously, scam enforcement often followed a linear path:

fraud → victim loss → delayed financial tracing → limited recovery

Under the new framework:

• The Secret Service can initiate investigations based on money-movement patterns alone.
• The FBI can pursue criminal conspiracies and human exploitation simultaneously.
• Financial seizures and infrastructure shutdowns can occur before full criminal attribution is complete.

This parallel model is far more disruptive to transnational scam networks, which depend on time, anonymity, and fragmentation to survive.

Strategic Implications for Transnational Scam Networks

For global scam organizations, this division of labor creates sustained pressure from two directions:

• The FBI targets leadership, recruitment, coercion, cyber access, and victim harm.
• The Secret Service targets payment corridors, laundering nodes, mule pipelines, and identity infrastructure.

The result is not just prosecution, but operational collapse. Even if scammers evade arrest, losing access to payment systems, remittance channels, or identity tools can cripple their ability to function.

What This Shift Signals at the Policy Level

This change reflects a broader realization by Congress:

• Modern scams are not merely frauds with financial consequences. They are financial enterprises that commit fraud.

By re-empowering the Secret Service as a lead financial crime agency, the law frees the FBI to concentrate on complex criminal ecosystems while ensuring that the economic engine of those ecosystems is systematically dismantled.

Bottom Line

The expanded Secret Service role does not diminish the FBI’s importance. It sharpens it.

The FBI becomes more focused on people, power, coercion, cybercrime, and victim harm.
The Secret Service becomes more focused on money movement, financial infrastructure, and systemic disruption.

Together, they form a coordinated enforcement model that is far better suited to dismantling transnational scam networks than either agency acting alone.

What This Means for Individual Scam Victims

The expanded role of the U.S. Secret Service does not change one essential fact for victims:

• You are not responsible for figuring out which federal agency investigates your case.
• The shift affects how cases are built and enforced inside the government. It does not move the burden onto victims.

What has changed is what happens after a report is made.

Who Victims Should Contact First

Local Law Enforcement

Victims should still begin by filing a report with local police or sheriff’s departments.

Why this still matters:

• It creates an official incident record.
• It is often required by banks, insurers, and recovery processes.
• It anchors jurisdiction for later federal involvement.

Even when local police cannot investigate international crimes directly, their report remains a critical first step.

The FBI’s Internet Crime Complaint Center (IC3)

Victims of online scams should file a report with the Internet Crime Complaint Center.

IC3 remains the primary intake point for:

• Romance scams
• Investment fraud
• Business email compromise
• Crypto-related scams
• Tech support scams

This does not change under the new law.

What does change is what happens next. IC3 data is now more likely to trigger parallel investigations, including Secret Service-led financial cases, even if victims never hear directly from those investigators.

Federal Trade Commission (FTC)

Victims should also report to the Federal Trade Commission.

The FTC:

• Tracks scam trends.
• Supports civil enforcement.
• Feeds intelligence into broader federal action.
• Helps shape future policy and enforcement priorities.

FTC reporting strengthens the collective response, even when individual cases cannot be prosecuted.

Should Victims Contact the Secret Service Directly?

In most cases, no.

This is a change. However, while it is understandable, the SCARS Institute recommends that victims contact the USSS as long as they will accept the report. This is because the USSS provides the best victim experience with law enforcment, which is fundamentally important for victims to regain a measure of control and confidence,

The Secret Service is not a victim intake agency. It rarely contacts victims directly unless:

• A case is already under active investigation.
• Financial infrastructure tied to the victim’s losses is being targeted.
• Asset seizure or restitution becomes possible.

Under the new law, the Secret Service is more likely to act behind the scenes, using financial data from banks, platforms, and reports to dismantle scam infrastructure.

Victims may never receive a call, even when action is taken. That silence does not mean nothing happened.

What Has Changed for Victims Behind the Scenes

The biggest change is not visibility, but effectiveness.

Before this law:

• Many cases stalled because transactions were small or fragmented.
• Informal payment systems fell outside clear enforcement authority.
• Financial facilitators avoided liability.

Now:

• Aggregated losses matter.
• Money movement patterns trigger investigations.
• Unlicensed payment operators face felony exposure.
• Financial infrastructure can be shut down earlier.

That increases the chance that:

• Scam operations are disrupted faster.
• Mule networks are dismantled.
• Payment corridors are closed.
• Future victims are protected.

It does not guarantee recovery of funds, but it improves the odds of systemic disruption.

Why Victims Often Do Not Hear Back

This is one of the hardest realities for victims.

Federal investigations:

• Can take months or years.
• Often involves sealed actions.
• May focus on infrastructure, not individual restitution.
• Prioritize disruption over communication.
• Law enforcement rarely, if ever, comments on ongoing investigations.

Silence does not mean disbelief, dismissal, or inaction.

It usually means:

• The information was logged.
• The data was correlated with other cases.
• Enforcement action, if any, is not public yet.

The Bottom Line for Victims

For victims, the reporting path remains simple:

1. Local law enforcement
2. FBI IC3
3. FTC

The expanded Secret Service role works behind the curtain, targeting the financial systems that make scams possible. Victims are not expected to navigate agency boundaries or understand jurisdictional shifts.

The system is changing so that your report does more, even if you never see the machinery move.

SCARS Institute Analysis

1. Core Structural Changes in Law Enforcement Tools

a) Aggregate Transactions & Course of Conduct Liability

• • The bill explicitly amends 18 U.S.C. § 1957 and related statutes to allow prosecutors to aggregate multiple small-value transactions into one laundering violation when they are connected by timing, parties, and purpose.
  • Why this matters: Traditional “smurfing” – breaking criminal proceeds into many transactions below reporting thresholds – is a signature tactic used not only by drug cartels and terror networks, but by international scam syndicates to disguise proceeds. Treating multiple connected transactions as a single laundering offense removes a key procedural loophole.
  • Impact on scam networks: Scam operations often split victim proceeds across dozens or hundreds of microtransactions (e.g., to avoid detection in banks or on crypto platforms). Prosecutors will now more easily characterize such behavior as an intentional course of criminal conduct.

b) Expanded Definitions to Encompass Modern Value Transfer Systems (VTS)

• • The legislation explicitly brings hawala, other informal VTS, crypto exchanges, and value substitutes into the scope of anti-money laundering law.
  • Impact on organized crimes: Transnational fraud rings, especially those operating in jurisdictions with minimal oversight, rely heavily on unregulated or informal value transfer systems to move funds offshore. Making these systems criminally actionable empowers prosecutors and agents to pursue cases they previously could not.

c) Reinstated Wiretap and Investigative Tools

• • The bill restores and expands wiretap authority for money laundering, bulk cash smuggling, illegal money service businesses (MSBs), and counterfeiting investigations.
  • Strategic effect: Transnational scammers often coordinate via encrypted communications. Enhanced wiretap authority – connected specifically to financial crime – allows law enforcement to penetrate network communications that were previously “off limits” under narrower statutes.

2. New Criminal Offenses and Categories

a) Illegal Money Services Business (MSB) as a Standalone Felony

• • Operating an MSB without proper licensing/compliance is now a felony regardless of knowledge or intent, with escalated penalties when volumes exceed defined thresholds or involve criminal proceeds.
  • Operational impact: Many scam ecosystems rely on informal remittance networks, unregistered payment processors, or “shadow” crypto services to repatriate illicit proceeds. This provision targets the infrastructure rather than just the scammers themselves.

b) Blank Check Transports and Cross-Border Evasion Schemes

• • Transporting blank bearer instruments that could be filled in later to avoid reporting is now treated as if they have value for reporting thresholds – blocking a classic evasion tactic.
  • Why this matters: Networks that move large volumes of illicit funds without entering traditional financial systems frequently resort to physical or semi-physical instruments. This closes a reporting gap.

c) Counterfeiting Tools as Enablers of Financial Crime

• • Possessing counterfeiting tools and materials becomes a felony that facilitates money laundering, synthetic identity fraud, mule recruitment, shell company creation, and fake KYCs.
  • Scam linkage: Organized scam operations often use synthetic identities and counterfeit credentials to set up accounts, payment channels, or cross-border mule networks.

3. Remittances and Supply Chain Analysis as a National Security Priority

• Treasury is mandated to map remittance flows used in drug trafficking, terrorism, human trafficking, and financial crime, producing a coordinated enforcement strategy with all relevant regulators.
• Scam relevance: International remittances – including those from diaspora, informal corridor networks, and third-party payment providers – are frequently exploited by scam syndicates to extract and launder proceeds. Formalizing this into a national security priority means that data collection and analytical capability will expand substantially.

4. International Reach, Foreign Banks, and Jurisdictional Authority

• The bill strengthens the authority to obtain records from foreign financial institutions and clarifies that foreign barriers cannot impede U.S. financial investigations when jurisdiction is established.
• This is a game-changer for transnational networks that base parts of their infrastructure in jurisdictions with weak compliance regimes or regulatory safeguards.

5. Broader Criminal Justice and Enforcement Implications

a) Course of Conduct Doctrine & Pattern-Based Prosecution

• • The shift toward prosecuting behavior patterns – rather than individual transactions – aligns anti-money laundering law with how sophisticated criminal networks actually operate.
  • This approach is especially effective against long-running scam syndicates that fractionate their financial flows to avoid detection.

b) Enhanced Interagency Tools and Coordination

• • Explicit Secret Service authority, expanded wiretap powers, and remittance analysis requirements indicate a more network-centric enforcement posture – moving beyond reactive investigations to proactive disruption.

6. Impact on Transnational Organized Crime and Global Scam Networks

Greater Enforcement Leverage Against Scam Syndicate Models:

1. Network Disruption Over Single Incident Prosecution: The law allows cases to be framed around a course of conduct, meaning entire networks of transactions and actors can be prosecuted as a single laundering enterprise.
2. Ancillary Infrastructure Is Now Criminal Target No. 1: 
   – Unlicensed MSBs, informal VTS, and shadow remittance networks will be treated as criminal infrastructure.
   – Operators – even without knowledge of scam linkage – risk felony charges.
3. Crypto and Alternative Value Flows Under AML’s Umbrella: Explicit inclusion of digital assets and substitute value transfer systems brings crypto mixers, decentralized protocols, and P2P transfers into the realm of enforceable money laundering statutes.
4. Cross-Border Operations Face Higher Risk: Enhanced reach into foreign banks and enforcement data sharing mechanisms builds pressure on jurisdictions that serve as safe havens for scam proceeds.
5. Counterfeiting and Synthetic Identity Law Reinforcement: By criminalizing possession of tools that facilitate identity fraud, the law disrupts the front-end mechanisms that scam networks use to establish financial personas and accounts.

7. Operational Challenges & Implementation Considerations

• Data and Analytics Capacity: Effective enforcement will depend on sophisticated pattern recognition (both public and private sector) to aggregate transactions and identify laundering schemes.
• International Coordination: Stronger U.S. law does not automatically compel cooperation from foreign regulators – although enhanced authority increases leverage.
• Compliance Burden on Financial Institutions: Banks, MSBs, and fintech providers will need to align policies with expanded definitions, increasing reporting and monitoring obligations.

Summary

The Combating Money Laundering, Terrorist Financing, and Counterfeiting Act of 2024 represents a fundamental shift in U.S. financial crime enforcement – from the prosecution of individual “bad acts” to the prosecution of behavioral patterns, network structures, and enabling infrastructures.

It aligns law with how modern criminal ecosystems, including transnational scam syndicates, actually operate:

• Aggregation of transactions eliminates classic smurfing tactics.
• Informal and crypto systems are now squarely within AML enforcement.
• Unlicensed payment infrastructure becomes a prosecutable offense.
• Counterfeiting, synthetic identity tools, and remittance flows are treated as part of the laundering supply chain.

Overall, this bill dramatically expands tools available to U.S. law enforcement and regulatory agencies to disrupt, dismantle, and prosecute sophisticated cross-border criminal enterprises – especially those whose financial flows have historically slipped through gaps in statutes written decades before modern financial technologies emerged.

The full text of the new law is below

Glossary

• Aggregate Transactions Doctrine — A prosecutorial approach that allows multiple small financial transfers to be treated as one laundering offense when they share timing, purpose, or participants. This closes a common loophole used by scam networks to hide proceeds through repeated low-value transfers that avoid reporting thresholds.
• Alternative Value Transfer Systems — Nontraditional methods of moving value outside formal banking channels, including informal networks and substitute instruments. These systems are frequently exploited by transnational scam operations to move funds across borders with limited oversight or documentation.
• Anti Money Laundering Statutes Expansion — Legislative changes that broaden existing money laundering laws to include modern payment methods and behaviors. This expansion aligns legal definitions with how contemporary financial crime actually operates in digital and cross-border environments.
• Behavior Pattern Prosecution — A legal strategy that focuses on repeated conduct and system-level activity rather than isolated criminal acts. This approach better reflects how organized scam networks function over time and across multiple victims.
• Blank Bearer Instruments — Financial documents that can be completed later to represent monetary value and evade reporting rules. Treating these instruments as having inherent value blocks a long-used method of cross-border laundering.
• Business Email Compromise Networks — Organized fraud schemes that hijack or imitate legitimate business communications to redirect payments. These schemes rely heavily on mule accounts and rapid money movement to avoid detection.
• Counterfeiting Tools as Financial Enablers — Equipment and materials used to produce fake documents or credentials that support fraud and money laundering. These tools enable scam networks to create synthetic identities and open accounts used to move illicit funds.
• Course of Conduct Liability — A legal concept that treats connected actions as part of a single criminal scheme. This reduces the burden of proving intent for each individual transaction within a broader laundering operation.
• Crypto Asset Inclusion — The explicit recognition of digital assets within money laundering enforcement frameworks. This removes ambiguity that previously allowed crypto-based laundering activity to fall into regulatory gray areas.
• Crypto On Ramp Infrastructure — Services that convert traditional currency into digital assets. Scam networks frequently exploit weak controls at these access points to move victim funds quickly into harder-to-trace channels.
• Decentralized Payment Pathways — Distributed financial routes that lack a single controlling institution. These pathways provide scammers with speed and anonymity but are increasingly targeted under expanded enforcement authority.
• Distributed Mule Networks — Groups of individuals recruited or coerced to move funds on behalf of criminal operations. Mule networks are central to scam scalability and are increasingly treated as core infrastructure rather than incidental participants.
• Economic Infrastructure Disruption — An enforcement strategy aimed at disabling the systems that allow crime to operate. This focuses on payment corridors and identity tools rather than solely pursuing individual offenders.
• Encrypted Communication Reliance — The use of secure messaging platforms by scam and money laundering networks to coordinate activity. Expanded investigative authority is designed to penetrate these coordination layers when linked to financial crimes.
• Financial Crime Reclassification — A policy shift that treats scams as system-based financial enterprises rather than isolated deception events. This reframing changes how investigations are prioritized and conducted.
• Financial Pattern Recognition — Analytical methods used to detect linked transactions across accounts and platforms. These tools are critical for identifying laundering activity that appears fragmented on the surface.
• Fragmented Payment Structuring — The deliberate splitting of funds into many small transfers to avoid detection. New aggregation authority directly targets this tactic used by scam syndicates.
• Hawala Style Transfer Networks — Informal value transfer systems operating on trust rather than formal records. These networks have historically been difficult to regulate and are now explicitly included in enforcement frameworks.
• Illegal Money Services Business — A payment operation that functions without required licensing or compliance. Treating this activity as a standalone felony targets the infrastructure that enables scams to function.
• Infrastructure First Enforcement — A strategic emphasis on dismantling systems before focusing on individual crimes. This approach aims to prevent future victimization by collapsing scam operations at scale.
• Interagency Role Rebalancing — A redistribution of investigative focus among federal agencies based on expertise. This allows financial specialists to target money flows, while others address human and organizational aspects of crime.
• Jurisdictional Barrier Reduction — Legal clarification that limits the ability of foreign secrecy laws to block investigations. This strengthens enforcement against cross-border scam networks.
• Know Your Customer Circumvention — Techniques used to bypass identity verification requirements. Synthetic identities and counterfeit documents are commonly used to defeat these controls.
• Layered Intermediaries — Multiple financial middlemen used to obscure the origin and destination of funds. Each layer adds distance between the crime and the proceeds.
• Money Movement Focus — A shift away from tracing funds after crimes toward monitoring how money flows. This enables earlier intervention before funds disappear offshore.
• National Security Financial Lens — The treatment of certain financial flows as security concerns rather than purely criminal matters. This elevates enforcement priority and coordination.
• Network Centric Investigations — Investigations designed to map relationships among actors and systems. This method reflects the reality of organized scam operations.
• Parallel Investigative Model — A framework that allows financial and criminal investigations to proceed simultaneously. This reduces delays and increases disruption effectiveness.
• Payment Corridor Mapping — The identification of common routes used to move illicit funds. Closing these corridors can disable multiple scam operations at once.
• Peer-to-Peer Payment Abuse — The misuse of direct transfer platforms to move scam proceeds quickly. These platforms are attractive to criminals due to speed and perceived anonymity.
• Predicate Offense Separation — The distinction between the underlying scam and the laundering activity that follows. Separating these elements allows specialized agencies to act more efficiently.
• Proactive Disruption Strategy — An enforcement philosophy focused on prevention rather than reaction. This strategy seeks to stop scams before widespread harm occurs.
• Remittance Flow Analysis — The systematic study of cross-border money transfers to identify misuse. Scam networks often rely on remittance channels to move funds internationally.
• Reporting Threshold Avoidance — The intentional structuring of transactions below mandatory reporting limits. Aggregation authority directly neutralizes this tactic.
• Shadow Payment Processors — Unregulated services that move funds outside formal oversight. These processors are a frequent backbone of large-scale scam operations.
• Smurfing Tactics — A laundering method involving many small transactions across accounts. Treating connected transfers as a single offense undermines this approach.
• Synthetic Identity Schemes — The creation of fictitious identities using real and fake data. These identities are used to open accounts and facilitate laundering.
• Systemic Scam Enablement — The collection of tools and services that allow scams to operate efficiently. Enforcement now targets these enablers as primary threats.
• Transnational Scam Syndicates — Organized groups operating across national borders to commit fraud. Their scale depends on flexible payment and identity infrastructure.
• Unlicensed Remittance Channels — Informal or illegal services used to move money internationally. Criminalizing these channels removes a key laundering pathway.
• Victim Impact Deprioritization — An enforcement reality where communication with victims may be limited during investigations. This reflects a focus on infrastructure disruption rather than individual case updates.
• Wiretap Authority Restoration — The reauthorization of surveillance tools for financial crime investigations. This enables access to coordination communications tied to laundering activity.
• Workflow-Based Crime Models — An understanding of scams as repeatable operational processes. This perspective supports pattern-based enforcement rather than isolated case analysis.

TEXT OF NEW LAW

118th CONGRESS
2d Session

S. 3643

To improve the prohibitions on money laundering, and for other purposes.

To improve the prohibitions on money laundering, and for other purposes.

Be it enacted by the Senate and House of Representatives of the United States of America in Congress assembled,

SECTION 1. Short title; table of contents.

Sec. 1. Short title; table of contents.
Sec. 2. Transportation or transhipment of blank checks in bearer form.
Sec. 3. Bulk cash smuggling.
Sec. 4. Section 1957 violations involving commingled funds and aggregated transactions.
Sec. 5. Charging money laundering as a course of conduct.
Sec. 6. Illegal money services businesses.
Sec. 7. Prohibiting money laundering through hawalas, other informal value transfer systems, and closely related transactions.
Sec. 8. Technical amendment to restore wiretap authority for certain money laundering and counterfeiting offenses.
Sec. 9. Making the international money laundering statute apply to tax evasion.
Sec. 10. Conduct in aid of counterfeiting.
Sec. 11. Danger pay allowance.
Sec. 12. Clarification of Secret Service authority to investigate money laundering.
Sec. 13. Remittances and money laundering threat analysis.
Sec. 14. Rule of construction.

SEC. 2. Transportation or transhipment of blank checks in bearer form.

“(e) Monetary instruments with amount left blank.—For purposes of this section, a monetary instrument in bearer form that has the amount left blank, such that the amount could be filled in by the bearer, and that is possessed by the bearer for the purpose of avoiding a reporting requirement, shall be considered to have a value of more than $10,000 if the instrument was drawn on an account that contained, or was intended to contain more than $10,000 at the time—

“(1) the instrument was transported; or

SEC. 5. Charging money laundering as a course of conduct.

SEC. 6. Illegal money services businesses.

“1960. Prohibition of illegal money services businesses.”.

“5330. Registration of money services businesses.”.

SEC. 8. Technical amendment to restore wiretap authority for certain money laundering and counterfeiting offenses.

SEC. 10. Conduct in aid of counterfeiting.

SEC. 12. Clarification of Secret Service authority to investigate money laundering.