ACAMS Today, September-November 2025 | Seite 24

AFC POLICY
and informal channels complicates detection. An analysis by the Financial Action Task Force( FATF) confirms that proceeds from synthetic-opioid trafficking are laundered through diverse schemes including bulk cash smuggling, trade-based laundering, shell companies and cryptocurrency conversion. 10 The sophisticated finance networks span continents and use both conventional and high-tech means to move drug proceeds.
Criminal finance networks
Illicit finance networks underpinning the fentanyl trade are complex and adaptive. In the supply chain, precursor chemicals and pill presses typically leave Chinese manufacturers for Mexican drug labs via U. S. postal and shipping routes. FinCEN reports that Mexico and the People’ s Republic of China are the top two foreign addresses in fentanyl-related suspicious activity reports( SARs). 11 The chemicals are often utilized to disguise shipments as legitimate imports through de minimis shipments. 12 Once fentanyl is produced( often in clandestine labs near the U. S. border), the finished product flows into U. S. and Canadian markets. Traffickers use multiple laundering layers: Bulk cash couriers and trade-based methods move profits out of source regions, while front businesses and professional money laundering organizations( including some tied to China-based networks) funnel the funds back
13, 14 into global financial channels.

Illicit finance networks underpinning the fentanyl trade are complex and adaptive

hubs. ​ 15 In Canada, methamphetamine proceeds and fentanyl profits flow through similar channels. Predominantly, trafficking groups structure payments to avoid detection: Individuals at the retail level commonly use cash or peer-to-peer( P2P) payments( e. g., apps, third-party transfers), while bulk shipments of funds are layered through foreign accounts and trade companies. Trade-based laundering is also emerging; for example, inflated import-export invoices can conceal value transfers.
Meanwhile, cartels are increasingly experimenting with new technologies. Organization for Security and Co-operation in Europe reports caution that generative artificial intelligence( GenAI) may soon enable traffickers to automate victim recruitment and recruitment narratives across languages and cultures. ​ 16 Already, scams run by forced labor victims( money mules) funnel illicit proceeds back to organizers. The United Nations Office on Drugs and Crime( UNODC) notes that traffickers have been coercing victims into sophisticated online fraud and cyber-scam operations, blending human trafficking with digital crime. 17 ​Such shifts mean anti-money laundering( AML) units must prepare for highly tech-savvy criminals who can
On the distribution side, U. S. firms in high-risk industries( e. g., cashintensive businesses, convenience stores, trucking) unwittingly serve as collection points. FinCEN’ s 2024 analysis emphasizes that populous U. S. states with major urban areas ― particularly California and Arizona’ s border counties ― see the highest fentanyl-related activity, reflecting established drug markets and cash flow
24 acamstoday. org