The main thrust of the bulletin, dated May 1, is that criminals and foreign adversaries of the U.S. “likely” use hedge funds, private equity and other investment vehicles to circumvent financial institutions’ anti-money-laundering (AML) procedures.

One of the four examples given by the FBI analysts involves a “fraudulent cryptocurrency investment scheme.” While the scheme is never named, the story told in the bulletin bears a striking resemblance to the OneCoin case. 

The FBI cited public information as well as “a human source with direct access” in its account. The bulletin’s other three examples of money laundering through private funds do not mention crypto.

Reuters first reported on the bulletin Tuesday. The bulletin is unclassified, but “law enforcement sensitive,” meaning it’s not supposed to be shared outside the federal government without FBI permission.

While OneCoin was a scam, the veiled references to Scott’s crimes in the FBI bulletin are a salient reminder that banks, not cryptocurrencies, were used to launder the ill-gotten gains.

Read the full memo below.


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