Financial Crimes

February 25, 2026

Overview of Two VERDICT Columns by Marci A. Hamilton on the Epstein Files*

Two recent opinion columns published on Justia Verdict – Legal Analysis and Commentary from Justia examine the legal, political, and moral implications of the continuing disclosures surrounding the Jeffrey Epstein investigations. Written by Professor Marci A. Hamilton of the University of Pennsylvania and founder of CHILD USA, the essays present a forceful argument that accountability for systemic abuse requires sustained legal pressure and public transparency. The views expressed are those of the author and do not represent the official position of Justia.

1. “The Three Avenues to Justice in the Epstein Cases” (Feb. 24, 2026)

In The Three Avenues to Justice in the Epstein Cases, Professor Hamilton argues that meaningful accountability is likely to emerge through three principal legal pathways rather than through federal prosecutorial initiative alone.

February 11, 2026

Better than the Real Thing? Promises and Perils of Synthetic Data: An Overview of Professor Peter Lee’s Essay Published in VERDICT

by David Badertscher

EXECUTIVE SUMMARY:

Professor Peter Lee’s VERDICT essay argues that synthetic data may revolutionize AI development by providing scalable, legally safer training material. Yet he warns that artificial datasets introduce new risks such as model collapse, bias, and misuse that demand proactive legal oversight. Rather than replacing existing regulatory debates, synthetic data transforms them, requiring courts, policymakers, and information professionals to rethink how innovation, privacy, and intellectual property intersect in the AI era

BETTER THAN THE REAL THING?

August 30, 2025

FinCEN Sounds the Alarm: Chinese Laundering Networks Empower Mexico-Based Cartels

by David Badertscher

The Financial Crimes Enforcement Center (FinCEN)”is a bureau of the U.S. Department of the Treasury. The Director of FinCEN is appointed by the Secretary of the Treasury and reports to the Treasury Under Secretary for Terrorism and Financial Intelligence. FinCEN’s mission is to safeguard the financial system from illicit activity, counter money laundering and the financing of terrorism, and promote national security through strategic use of financial authorities and the collection, analysis, and dissemination of financial intelligence.”.

On June 25, 2025, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) imposed special measures under Section 9714 of the Fentanyl Sanctions Act and the FEND Off Fentanyl Act, designating three Mexico-based financial institutions, CIBanco, Intercam Banco, and Vector Casa de Bolsa , as primary money laundering concerns. The action prohibits US financial institutions from processing transmittals of funds to or from these entities, or to any account or digital asset address they administer. This marks the first use of these new authorities, aimed at disrupting financial infrastructure exploited by cartels for fentanyl trafficking and precursor procurement.

According to FinCEN’s findings, the designated institutions played a key role in laundering funds on behalf of major cartels including CJNG, the Gulf Cartel, the Beltran-Leyva Organization, and the Sinaloa Cartel. The institutions processed millions of dollars in payments to China-based suppliers of precursor chemicals used in fentanyl production. Examples include a 2023 incident in which a CIBanco employee knowingly created an account to launder USD 10 million for a Gulf Cartel member, and Intercam executives meeting with CJNG associates to design laundering schemes involving US dollar wire transfers to China. Vector was linked to over USD 2 million in laundered proceeds for the Sinaloa Cartel, and over USD 1 million in payments to Chinese chemical exporters from 2018 to 2023. From TRM Blog June 25, 2025.