Debt & Duty

Cartels generate billions of dollars in the United States from drug trafficking, human trafficking and human smuggling, and other criminal activity. As Chinese Money Laundering Networks (CMLNs) represent an increasing proportion of cartel laundering, CMLNs target students to function as money mules. CMLNs use cultural obligation, debt bondage from rigged games at illegal casinos, and financial rewards to induce students to participate.

“Chinese students may be vulnerable to recruitment and exploitation as money mules by U.S.-based CMLNs, which need access to, and control of, many bank accounts to facilitate frequent cash deposits to place illicit proceeds into the U.S. financial system…” – FinCEN Financial Trend Analysis August 2025

A 2025 advisory from FinCEN highlights the scale of CMLN operations targeting students. From 2020-2024, more than 20,000 suspicious activity reports referencing individuals purporting to be Chinese students were filed by U.S. financial institutions. These reports represented approximately $13.8 billion in suspicious activity and were filed from multiple financial sectors including banks, MSBs, and casinos.

The laundering networks operated by CMLNs are extensive. In the United Kingdom, the National Crime Agency identified a network controlling 600 accounts at a single bank – and more accounts at multiple other financial institutions controlled by the same CMLN.

Chinese Money Laundering Networks: Recruitment and Control of Students

The methods used by CMLNs to recruit and control students have similarities across jurisdictions.

In the United States, FinCEN assessed that the reasons Chinese students could become involved included financial returns and obligations towards the Chinese community.

“CMLNs appear to have increasingly recruited Chinese students studying at U.S. universities, and some of these students may have continued to participate in CMLN operations after graduating… In some cases, individuals recruited by CMLNs may not understand that their actions are illegal, but rather were lured into participating in the schemes under the incentive of having a source of income and assisting other Chinese citizens or nationals in accessing U.S. dollars (USD).” – FinCEN Advisory

Similar patterns are seen in other countries. In the United Kingdom, Chinese students are recruited as money mules by being told they are providing transmission services for other students or unbanked Chinese citizens in the UK, accordingly to the UK National Crime Agency.

Chinese students may be coerced into being money mules, for example through “debt bondage” from gambling losses at illegal casinos (as described in the real-life example below). However, in many situations students are simply asked to undertake illicit activity, against a backdrop of cultural expectations and obligations.

A 2023 survey* of Chinese students in the United Kingdom undertaken by the UK Home Office Modern Slavery and Organised Crime Team identified that where students were targeted by Chinese criminal networks, many felt obligated to comply if they were simply asked. The key findings include:

• The survey focused on the specified activities of laundering money through their personal bank account and accepting packages of illicit substances.
• 5% of Chinese students in the UK had been asked or coerced by a person of their own ethnicity to undertake these activities. 1 out of 4 had been coerced – the remaining 3 were simply asked.
• 9% responded that they would feel compelled or highly compelled to assist if asked by a person of their own ethnicity.

* The preliminary findings from the study are used here with permission of the author, David Wilson.

As well as being recruited as mules to launder funds through financial institutions, CMLNs recruit students to act as buyers in daigou schemes as well as to launder money through casinos and gaming, real estate, healthcare, and other industries, and combinations of these.

Real-Life Investigation: Illegal Casinos and Debt Bondage

An investigation by the West Midlands Police in the United Kingdom identified that overseas students were being targeted by criminal networks in illegal casinos using “rigged” games. For example, in one investigation the cards at the poker table were marked, then the play was monitored by a covert infrared camera. The information was relayed to another player, who used it to cheat the other players out of cash. The West Midlands Police identified that the criminal networks gained influence over students through their gambling debts, using this to coerce them into criminality.