TRM Labs Exposes Chinese Underground Banking as Backbone of Illicit Finance

In a report titled All Roads Lead to China, TRM Labs, a blockchain intelligence firm, has unveiled the intricate web of Chinese underground banking networks that have emerged as the financial linchpin of global illicit activities.

These networks, leveraging both traditional and modern financial mechanisms, are facilitating billions of dollars in criminal enterprises, from cryptocurrency laundering for North Korean hackers to enabling fentanyl trafficking by Mexican cartels and Triad-run casinos.

The report underscores the sophistication and scale of these operations, positioning them as the world’s formidable underground financial pipeline.

At the heart of these networks is the ancient practice of fei qian—literally “flying money”—a system of informal value transfer that predates modern banking.

Historically used to move funds discreetly, fei qian has evolved with the digital age, incorporating cryptocurrencies to enable rapid, borderless transactions.

TRM Labs highlights how these networks exploit crypto’s anonymity to launder vast sums, often bypassing traditional financial oversight.

The report details their role in one of the largest crypto heists to date: the Bybit hack, where over-the-counter (OTC) brokers in China and Hong Kong facilitated the laundering of stolen digital assets, primarily linked to North Korean cybercriminal groups.

This incident alone underscores the networks’ capacity to handle high-stakes financial crime with alarming efficiency.

The convergence of cybercrime, narco-trafficking, and sanctions evasion marks a new era of global illicit finance, with Chinese underground banks serving as a critical nexus.

The report reveals how these networks enable a symbiotic relationship between state and non-state actors, including North Korea and Russia, to evade international sanctions.

By integrating trade-based money laundering, shell companies, and crypto mixers—tools that obscure transaction trails—these networks create a nearly impenetrable financial ecosystem.

For instance, Mexican cartels rely on these channels to launder proceeds from fentanyl trafficking, while Triad organizations use them to funnel profits from illicit gambling operations.

This interconnected web not only amplifies the scale of financial crime but also challenges traditional law enforcement approaches.

Law enforcement agencies worldwide are recognizing Chinese underground banking as a top-tier threat.

The report cites officials describing these networks as the “most formidable underground financial pipeline” due to their adaptability and global reach.

Unlike centralized financial institutions, these decentralized systems operate through trusted intermediaries, making them difficult to trace and dismantle.

TRM Labs emphasizes that disrupting these networks requires a multifaceted strategy, including enhanced blockchain analytics, international cooperation, and targeted sanctions against key facilitators.

The report also advocates for stronger regulatory frameworks to address the misuse of crypto mixers and OTC brokers, which serve as critical nodes in the laundering process.

TRM Labs’ findings come at a critical juncture, as global regulators and law enforcement grapple with the evolution of financial crime.

By mapping the intricate connections between various networks, crypto laundering, and transnational crime syndicates, the report offers a roadmap for combating this growing threat.

However, the challenge remains daunting: stopping these networks will require coordination and innovation to outpace their adaptability.

As TRM Labs concludes, understanding and disrupting this ecosystem is not just a financial imperative but a matter of global security.



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Disclosure Quest

Reg A - Form 1-A Filings Beta

Beta. Initial Form 1-A only. Target raise is the stated Amount to be Raised, totaled. Compared with the same dates one year earlier.

YTD: Jan 1, 2026 - Nov 4, 2026 vs Jan 1, 2025 - Nov 4, 2025

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Number of Filings134Prior 129 +3.9%
Target Raise, Total$3.45BPrior $3.59B -3.8%
This YTDYear priorChange
Filings 134 129 +3.9%
Target raise $3.45B $3.59B -3.8%

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