US Congressional Library report on US sanctions on Chinese Money Laundering Networks

9 January 2026

The US Congressional Research Service, part of the Library of Congress, has published a briefing report on Chinese Money Laundering Networks (CMLNs) and US sanctions. The report says:

• CMLNs have emerged as a foreign policy concern because they evade Chinese currency controls and launder proceeds for transnational criminal organisations said to be involved in fentanyl trafficking including the Sinaloa Cartel, a US-designated Foreign Terrorist Organisation.

• In one case study, the US Department of Justice identified a CMLN laundering funds for the Sinaloa Cartel. In July 2024, the US imposed sanctions on three people linked to the CMLN.
• Sanctions targeting CMLNs draw on the Fentanyl Sanctions Act, which was evoked in EO 14059, part of the US narcotics sanctions regime.

• The BUST Fentanyl Act, which was passed as part of the 2026 National Defense Authorization Act, could in future be used to further target Chinese people and entities involved in fentanyl trafficking. It also authorises the imposition of fentanyl-related sanctions on agencies of foreign states.