III 

117TH CONGRESS 

2D SESSION S. RES. 610 

Expressing the sense of Congress that the activities of transnational criminal 

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

trade-based money laundering, pose a threat to the national interests 

and national security of the United States and allies and partners of 

the United States around the world. 

IN THE SENATE OF THE UNITED STATES 

MAY 3, 2022 

Mr. CASSIDY (for himself, Ms. SINEMA, Mr. CORNYN, Mr. GRAHAM, Mr. 

MENENDEZ, Mr. WYDEN, Mr. WHITEHOUSE, Mr. RUBIO, and Mr. 

YOUNG) submitted the following resolution; which was referred to the 

Committee on Banking, Housing, and Urban Affairs 

RESOLUTION 

Expressing the sense of Congress that the activities of 

transnational criminal organizations, including the use 

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

laundering, pose a threat to the national interests and 

national security of the United States and allies and 

partners of the United States around the world. 

Whereas trade-based money laundering is among the most 

widely used and least understood forms of money laundering, disguising proceeds of crime by moving value 

through international trade transactions in an attempt to 

legitimize illicit origins of money or products; 


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•SRES 610 IS 

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

exceedingly difficult; 

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

have succeeded at trade-based money laundering despite 

the best 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, and constitutes a persistent threat to the economy 

and security of the United States; 

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

undervaluation of imports and 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, threatening 

the quality and safety of consumer, industrial, and military products; 

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 


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•SRES 610 IS 

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; 

Whereas trade-based money laundering undermines national 

security and the rule of law in countries where it takes 

place; 

Whereas illicit profits for transnational criminal organizations 

and other criminal organizations can lead to instability 

globally; 

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 intrinsic connection to international threat networks, as well as the use of licit trade to further their 

motives, is a national security concern; 

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; 


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•SRES 610 IS 

Whereas United States ports and U.S. Customs and Border 

Protection do not have the capacity to properly examine 

the 60,000,000 shipping containers that pass through 

United States ports annually, with only 2 to 5 percent of 

that cargo actively inspected; 

Whereas trade-based money laundering can only 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 almost 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 threat to the national inVerDate Sep 11 2014 01:51 May 04, 2022 Jkt 029200 PO 00000 Frm 00004 Fmt 6652 Sfmt 6201 E:\BILLS\SR610.IS SR610

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1 terests and national security of the United States 

2 and allies and partners of the United States around 

3 the world; 

4 (2) in addition to considering the countering of 

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

6 laundering as a national priority and committing to 

7 detect, address, and prevent such activities, the 

8 President should— 

9 (A) continue to assess, in the periodic na10 tional risk assessments on money laundering, 

11 terrorist financing, and proliferation financing 

12 conducted by the Department of the Treasury, 

13 the ongoing risks of trade-based money laun14 dering; 

15 (B) finalize the assessment described in 

16 the Explanatory Statement accompanying the 

17 Financial Services and General Government Ap18 propriations Act, 2020 (division C of the Con19 solidated Appropriations Act, 2020 (Public Law 

20 116–93)), which directs the Financial Crimes 

21 Enforcement Network of the Department of the 

22 Treasury to thoroughly assess the risk that 

23 trade-based money laundering and other forms 

24 of illicit finance pose to national security; 


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1 (C) work expeditiously to develop, finalize, 

2 and execute a strategy, as described in section 

3 6506 of the Anti-Money Laundering Act of 

4 2020 (title LXV of division F of Public Law 

5 116–283; 134 Stat. 4631), drawing on the mul6 tiple instruments of United States national 

7 power available, to counter— 

8 (i) the activities of transnational 

9 criminal organizations, including illicit 

10 trade and trade-based money laundering; 

11 and 

12 (ii) the illicit economies such organiza13 tions operate in; 

14 (D) coordinate with international partners 

15 to implement that strategy, exhorting those 

16 partners to strengthen their approaches to com17 bating transnational criminal organizations; and 

18 (E) review that strategy on a biennial basis 

19 and improve it as needed in order to most effec20 tively address illicit economies, illicit trade, and 

21 trade-based money laundering by exploring the 

22 use of emerging technologies and other new 

23 avenues for interrupting and putting an end to 

24 those activities; and 


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1 (3) the Trade Transparency Unit program of 

2 the Department of Homeland Security should take 

3 steps to strengthen its work, including in countries 

4 that the Department of State has identified as major 

5 money laundering jurisdictions under section 489 of 

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

7 2291h). 

Æ 


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