The Treasury Department released the 2026 National Money Laundering Risk Assessment on Saturday, identifying offshore trusts as the single highest-risk vehicle for sanctions evasion, tax fraud, and kleptocracy — surpassing shell companies for the first time.
The assessment, which is required by Congress every four years, found that the use of offshore trusts in jurisdictions like the Cook Islands, Nevis, and Belize has increased 140% since 2022. Unlike shell companies, trusts typically have no public filing requirements and often have no named trustees or beneficiaries in any accessible registry.
'Trusts are the black boxes of the financial system,' the report states. 'Law enforcement often cannot determine who controls trust assets without months of expensive litigation, by which time assets have been moved.'
Policy recommendations
The assessment recommends that Congress pass legislation requiring trusts that own U.S. real estate or accounts to file beneficial ownership information with FinCEN, similar to the Corporate Transparency Act. It also recommends expanding anti-money laundering rules to cover trust and company service providers.
The American Bankers Association expressed support for the trust recommendations. However, the U.S. Chamber of Commerce opposed them, arguing that 'legitimate estate planning would be burdened.'
Trusts are the black boxes of the financial system. Law enforcement often cannot determine who controls trust assets without months of expensive litigation.
The assessment also noted that cryptocurrency mixing services remain a 'critical vulnerability,' but that their overall volume ($2.4 billion in 2025) is dwarfed by offshore trust flows (estimated at $80 billion).
