Keeping an Eye on the Federal Civil Money Laundering Statute

After the adoption in 1986 of the Money Laundering Control Act (MLCA), 18 U.S.C. §§ 1956-1957, money laundering quickly became, to borrow Judge Learned Hand’s phrase, another darling of the modern federal prosecutor’s nursery. Every year, federal prosecutors file many hundreds of criminal money laundering cases. The charge can appear in a dizzyingly wide array of contexts, as the MLCA’s definition of the necessary underlying “specified unlawful activity,” or SUA, extends to literally hundreds of different crimes.