III 

117TH CONGRESS 

2D SESSION S. RES. 874 

Expressing the sense of the Senate that the activities of transnational criminal 

organizations, including the use of illicit economies, illicit trade, and 

trade-based money laundering, pose a risk to the interests of the United 

States and allies and partners of the United States around the world. 

IN THE SENATE OF THE UNITED STATES 

DECEMBER 19, 2022 

Mr. CASSIDY (for himself, Mr. WHITEHOUSE, and Mr. WYDEN) submitted the 

following resolution; which was considered and agreed to 

RESOLUTION 

Expressing the sense of the Senate that the activities of 

transnational criminal organizations, including the use 

of illicit economies, illicit trade, and trade-based money 

laundering, pose a risk to the interests of the United 

States and allies and partners of the United States 

around the world. 

Whereas trade-based money laundering is a form of money 

laundering that disguises proceeds of crime by moving 

value through international trade transactions; 

Whereas the transnational nature and complexity of tradebased money laundering make detection and investigation 

difficult; 


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•SRES 874 ATS 

Whereas drug trafficking organizations, terrorist organizations, and other transnational criminal organizations 

have succeeded at trade-based money laundering despite 

the efforts of United States law enforcement; 

Whereas trade-based money laundering includes other offenses such as tax evasion, disruption of markets, profit 

loss for businesses, and corruption of government officials; 

Whereas trade-based money laundering can result in the decreased collection of customs duties as a result of fraudulent cargo manifests; 

Whereas trade-based money laundering can decrease tax revenue collected as a result of the sale of underpriced goods 

in the marketplace; 

Whereas trade-based money laundering is one mechanism by 

which counterfeiters infiltrate supply chains; 

Whereas drug trafficking organizations collaborate with Chinese criminal networks to launder profits from drug trafficking through Chinese messaging applications; 

Whereas, on March 16, 2021, the Commander of the United 

States Southern Command, Admiral Faller, testified to 

the Committee on Armed Services of the Senate that 

transnational criminal organizations ‘‘market in drugs 

and people and guns and illegal mining, and one of the 

prime sources that underwrites their efforts is Chinese 

money-laundering’’; 

Whereas the deaths and violence associated with drug traffickers, the financing of terrorist organizations and other 

violent non-state actors, and the adulteration of supply 

chains with counterfeit goods showcase the danger tradebased money laundering poses to the United States; 


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Whereas trade-based money laundering undermines security 

and the rule of law in countries where it takes place; 

Whereas the United States is facing a drug use and overdose 

epidemic, as well as an increase in consumption of synthetic drugs, such as methamphetamine and fentanyl, 

which is often enabled by Chinese money laundering organizations operating in coordination with drug-trafficking organizations and transnational criminal organizations in the Western Hemisphere that use trade-based 

money laundering to disguise the proceeds of drug trafficking; 

Whereas the presence of drug traffickers in the United States 

and their connection to international threat networks, as 

well as the use of licit trade to further their motives; 

Whereas drug-trafficking organizations frequently use the 

trade-based money laundering scheme known as the 

‘‘Black Market Peso Exchange’’ to move their ill-gotten 

gains out of the United States and into Central and 

South America; 

Whereas trade-based money laundering can be combated effectively if the intelligence community, law enforcement 

agencies, the Department of State, the Department of 

Defense, the Department of the Treasury, the Department of Homeland Security, the Department of Justice, 

and the private sector work together; 

Whereas drug-trafficking organizations, terrorist organizations, and other transnational criminal organizations disguise the proceeds of their illegal activities behind sophisticated mechanisms that operate seamlessly between licit 

and illicit trade and financial transactions, making it alVerDate Sep 11 2014 16:04 Dec 20, 2022 Jkt 039200 PO 00000 Frm 00003 Fmt 6652 Sfmt 6300 E:\BILLS\SR874.ATS SR874

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most impossible to address without international cooperation; and 

Whereas the United States has established Trade Transparency Units with 18 partner countries, including with 

major drug-producing and transit countries, to facilitate 

the increased exchange of import-export data to combat 

trade-based money laundering: Now, therefore, be it 

1 Resolved, That it is the sense of the Senate that— 

2 (1) the activities of transnational criminal orga3 nizations and their networks, and the means by 

4 which such organizations and networks move and 

5 launder their ill-gotten gains, such as through the 

6 use of illicit economies, illicit trade, and trade-based 

7 money laundering, pose a risk to the interests of the 

8 United States and allies and partners of the United 

9 States around the world; 

10 (2) in addition to considering the countering of 

11 illicit economies, illicit trade, and trade-based money 

12 laundering as a national priority and committing to 

13 detect, address, and prevent such activities, the 

14 President should— 

15 (A) continue to assess, in the periodic na16 tional risk assessments on money laundering, 

17 terrorist financing, and proliferation financing 

18 conducted by the Department of the Treasury, 

19 the ongoing risks of trade-based money laun20 dering; 


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1 (B) finalize the assessment described in 

2 the Explanatory Statement accompanying the 

3 Financial Services and General Government Ap4 propriations Act, 2020 (division C of the Con5 solidated Appropriations Act, 2020 (Public Law 

6 116–93)), which directs the Financial Crimes 

7 Enforcement Network of the Department of the 

8 Treasury to thoroughly assess the risk that 

9 trade-based money laundering and other forms 

10 of illicit finance pose to the United States; 

11 (C) work expeditiously to develop, finalize, 

12 and execute a strategy, as described in section 

13 6506 of the Anti-Money Laundering Act of 

14 2020 (title LXV of division F of Public Law 

15 116–283; 134 Stat. 4631)), to counter— 

16 (i) the activities of transnational 

17 criminal organizations, including illicit 

18 trade and trade-based money laundering; 

19 and 

20 (ii) the illicit economies such organiza21 tions operate in; 

22 (D) coordinate with international partners 

23 to implement that strategy, exhorting those 

24 partners to strengthen their approaches to com25 bating transnational criminal organizations; and 


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1 (E) review that strategy on a biennial basis 

2 and improve it as needed in order to most effec3 tively address illicit economies, illicit trade, and 

4 trade-based money laundering by exploring the 

5 use of emerging technologies and other new 

6 avenues for interrupting and putting an end to 

7 those activities; and 

8 (3) the Trade Transparency Unit program of 

9 the Department of Homeland Security should take 

10 steps to strengthen its work, including in countries 

11 that the Department of State has identified as major 

12 money laundering jurisdictions under section 489 of 

13 the Foreign Assistance Act of 1961 (22 U.S.C. 

14 2291h). 

Æ 


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