Why American Law Enforcement Must Investigate Criminal Networks, Not Just Crimes

The crime in front of an investigator may be only one node in a much larger transnational criminal ecosystem. 

A local police department receives information that commercial sex is occurring inside a massage business. Investigators conduct surveillance, develop probable cause, and conduct an undercover operation. Prostitution is confirmed. Arrests are made, evidence is seized, and cases are filed. By traditional measures, the investigation was successful.

But what if the prostitution offense was never the most important thing investigators discovered?

Who owns the business? Who financed it? Who recruited the women working there? Where did those women live before arriving? Who transported them? Where will they go next? Who controls advertising? Who receives the proceeds? Are the same telephone numbers, bank accounts, vehicles, addresses, advertisers, managers, corporate entities, or financial facilitators connected to businesses in other jurisdictions? Who is moving the money, and where does that money ultimately go?

Those questions represent an important shift in how American law enforcement should approach modern organized crime. Investigating the offense may solve the case. Investigating the network may reveal the threat.

American law enforcement is necessarily structured around jurisdictions, statutory authorities, and specialized investigative responsibilities. Vice investigators investigate prostitution. Narcotics units investigate drugs. Financial-crimes investigators follow fraud and money laundering. Cyber investigators examine online offenses. Human-trafficking investigators focus on exploitation. Federal authorities may investigate immigration violations and transnational criminal activity. Intelligence units attempt to identify broader threats. Criminal organizations have no obligation to respect those organizational charts.

Increasingly, activities presenting locally as prostitution, illicit massage, illegal gambling, fraud, immigration violations, narcotics trafficking, cybercrime, or money laundering may represent individual nodes within larger transnational ecosystems involving human trafficking, professional money laundering organizations, shell companies, legitimate commercial enterprises, cryptocurrency, foreign-based facilitators, and underground financial systems.

The United States is already seeing evidence of this convergence.

In August 2025, the Financial Crimes Enforcement Network raised an alarm regarding Chinese money laundering networks, or CMLNs, describing them as a significant threat to the U.S. financial system. FinCEN’s analysis examined more than 137,000 Bank Secrecy Act reports filed between 2020 and 2024 associated with suspected CMLN activity representing approximately $312 billion in suspicious transactions.

Importantly, FinCEN did not describe these organizations as participating solely in laundering drug proceeds. The agency identified suspected CMLN activity associated with fraud, human trafficking, human smuggling, and the laundering of proceeds for Mexico-based drug cartels.

That should matter to the patrol officer, vice investigator, human-trafficking detective, narcotics investigator, financial-crimes investigator, intelligence analyst, and federal agent alike. Each may encounter a different doorway into the same criminal ecosystem.

Recent analysis concerning organized crime and triad developments in Macau provides another useful warning about the changing nature of organized crime. The lesson for American law enforcement is not that every Chinese criminal organization operating in the United States is a traditional triad, nor should Chinese criminal networks automatically be associated with the government of the People’s Republic of China.

The Congressional Research Service has specifically cautioned against that assumption. U.S. government terminology surrounding Chinese money laundering organizations generally refers to third-party laundering networks with links to the PRC and does not, by itself, establish a relationship between those organizations and the Chinese government or Chinese Communist Party.

That distinction is important. But another distinction is equally important: modern transnational organized crime does not necessarily resemble the organized crime American investigators have traditionally been trained to recognize.

The familiar image is hierarchical: identifiable leadership, defined membership, territory, and recognizable criminal activity. Contemporary criminal ecosystems can be considerably more fluid. Different participants may provide specialized services involving money laundering, transportation, recruitment, advertising, cryptocurrency conversion, banking, communications, housing, fraudulent documentation, or access to legitimate businesses without every participant belonging to one monolithic criminal organization.

The intelligence question therefore should not always be, “Is this person a member of a particular criminal organization?”

Increasingly, the better question may be: What criminal ecosystem is this person, business, account, device, or transaction connected to?

Consider again the illicit massage business.

A conventional prostitution investigation may identify a woman engaged in commercial sex and the customer purchasing it. A network-based investigation may reveal something considerably different.

In January 2026, federal prosecutors in Pennsylvania announced the indictment of four Chinese nationals following an investigation involving two illicit massage businesses in Erie. The charges included allegations involving human trafficking, immigration violations, prostitution, interstate transportation, and money laundering. Prosecutors alleged that individuals engaged in prostitution lived at or adjacent to commercial properties and that members of the organization transported individuals between states.

Other federal investigations involving massage businesses have documented similar combinations of recruitment, commercial-sex advertising, transportation, financial transactions, interstate movement, and the use of multiple businesses. In a Texas and New Mexico investigation, federal authorities identified an operator associated with at least seven massage businesses. Court records described women being transported from airports directly to massage establishments, commercial-sex advertising, interstate operations, and substantial proceeds. The principal defendant was ultimately ordered to forfeit nearly $292,000 in currency and pay a money judgment exceeding $1.7 million.

In another case, a Chinese national pleaded guilty in March 2026 to conspiracy to commit money laundering involving proceeds from a prostitution enterprise operating several spas in New York’s Capital Region. According to federal prosecutors, the spas generated more than $2 million in proceeds, with funds laundered through third parties and used to purchase assets, including real estate.

Viewed individually, each establishment might initially appear to be a local prostitution problem. Viewed as a network, the investigative picture changes.

The massage business becomes a node connecting people, transportation, communications, advertising, financial transactions, corporate entities, real estate, and potentially other businesses and jurisdictions.

The concept extends far beyond illicit massage. A bank account can be a node. A cryptocurrency wallet can be a node. A hotel room can be a node. A commercial-sex advertisement can be a node. A shell corporation can be a node. A casino transaction, vehicle, telephone number, social-media account, property, or money courier can be a node. The critical question becomes what else connects to it. That also requires investigators to look beyond offenders and toward facilitators.

Who provides transportation? Who establishes corporations? Who manages advertising? Who controls communications? Who recruits workers? Who provides housing? Who processes payments? Who collects cash? Who converts cryptocurrency? Who purchases property? Who moves proceeds internationally?

Those actors may be more strategically important than the people committing the most visible predicate offense. Removing one offender can disrupt one portion of an enterprise. Identifying the infrastructure supporting dozens of offenders can expose the enterprise itself.

Recent U.S. investigations into Chinese money laundering organizations demonstrate why this matters.

In 2024, the Department of Justice announced charges arising from an alleged alliance between Sinaloa Cartel associates and money launderers connected to Chinese underground banking. More than $50 million in drug proceeds allegedly flowed through the arrangement. Investigators described trade-based money laundering, structured transactions, cryptocurrency, underground banking, luxury goods, and other mechanisms used to move value while satisfying two different demands: Mexican criminal organizations needed to convert U.S. drug proceeds into usable funds, while some Chinese nationals sought access to U.S. dollars outside China’s currency-control system.

Two seemingly separate problems found each other.

Federal investigations since then have continued to expose transnational laundering structures involving Chinese nationals, Mexican cartels, foreign bank accounts, encrypted communications, bulk-cash collection, trade-based money laundering, and international financial facilitators. In 2025, members of one Chinese money laundering organization pleaded guilty in a scheme involving more than $92 million in illicit funds, including drug-trafficking proceeds.

In May 2026, federal prosecutors announced charges against two Chinese nationals in an alleged money-laundering conspiracy involving the Sinaloa Cartel and Cartel de Jalisco Nueva Generación. According to DOJ, the alleged organization used mirror transfers, foreign bank accounts, encrypted communications, serial-number verification systems, and trade-based money laundering across the United States, Mexico, Latin America, China, and elsewhere.

The lesson extends beyond narcotics.

FinCEN’s findings are particularly instructive because the agency has identified suspected Chinese money laundering networks not merely in connection with narcotics proceeds but also with fraud, human trafficking, and human smuggling.

In July 2026, federal prosecutors charged two alleged members of a Chinese money laundering network with laundering at least $43 million derived from cyber-enabled investment fraud. According to the indictment, the organization used more than a dozen individuals, approximately 140 bank accounts, and approximately 45 shell companies before allegedly working with China-based co-conspirators to transfer funds abroad

Place those criminal markets beside one another: drug trafficking, human trafficking, commercial sexual exploitation, cyber-enabled fraud, shell corporations, underground banking, trade-based money laundering, cryptocurrency, and foreign financial relationships. None should automatically be assumed to belong to the same criminal organization.

But investigators should not automatically assume they are unrelated simply because the predicate offenses are different. Shared infrastructure may sometimes be more important than shared crime type.

That should become an increasingly important principle for American intelligence collection.

Suppose investigators identify a telephone number during a prostitution investigation. The traditional investigative question may be whether that telephone number helps establish an element of the prostitution offense.

The network question is larger.

What other advertisements use it? What businesses are associated with it? What accounts were created using it? What other numbers communicate with it? What locations are associated with those communications? What financial accounts intersect with those entities? Does another investigation contain the same identifier? Has another agency encountered it? Does it connect to another state or another country?

The same methodology can be applied to names, email addresses, bank accounts, vehicles, corporate registrations, advertising accounts, cryptocurrency wallets, property records, travel patterns, and other identifiers.

This does not mean every prostitution arrest should become a federal organized-crime investigation. It means investigators should recognize when indicators suggest that the offense in front of them may be a gateway into something larger.

There is a difference between case development and network development. Both are important, but they answer different questions.

Geographic movement should also increasingly be treated as intelligence.

When individuals repeatedly move among businesses, cities, or states, investigators should consider whether that mobility reveals organizational infrastructure. The same principle applies to cash couriers, suspected traffickers, recruiters, commercial-sex providers, vehicles, managers, and financial intermediaries.

A person encountered once in one jurisdiction may mean little beyond that investigation. The same person appearing in five investigations across several jurisdictions becomes intelligence.

Likewise, one business operating independently may reveal little about a broader organization. Multiple businesses sharing workers, telephone numbers, advertisers, bank accounts, vehicles, managers, corporate officers, addresses, or financial facilitators present a very different picture.

Local agencies are uniquely positioned to discover these connections because local officers routinely encounter the physical nodes of transnational networks: businesses, people, vehicles, victims, customers, cash, property, and electronic devices.

The challenge is ensuring that intelligence does not remain trapped inside individual case files. There is also a national-security dimension that deserves greater attention. Foreign-linked organized crime does not have to be controlled by a foreign government to create national-security vulnerabilities.

That distinction should be made clearly. There is no justification for assuming that every Chinese organized-crime or money-laundering network operates on behalf of the Chinese government. Making that assumption without evidence risks undermining legitimate investigations and legitimate national-security concerns. But foreign-linked criminal infrastructure can nevertheless create opportunities for exploitation.

Criminal networks may develop access to substantial financial information, communications, businesses, property, personal information, compromising information, transportation infrastructure, and individuals occupying sensitive positions. That becomes especially important when criminal activity intersects geographically or socially with military installations, defense contractors, ports, airports, critical infrastructure, government facilities, sensitive technology industries, or research institutions.

The counterintelligence question is therefore broader than whether a foreign government currently directs a criminal enterprise. The question is whether that network creates access, placement, leverage, information, or vulnerability that another actor could exploit. That is fundamentally different from determining whether probable cause exists to make a prostitution arrest.

Both questions matter. Only one looks beyond tomorrow’s docket.

American law enforcement understandably measures success through tangible outcomes: arrests, indictments, convictions, seizures, and victims identified. Those measurements remain important. But network investigations require another measure of success:

What did we learn?

Ten arrests may produce ten defendants. One properly exploited telephone, financial account, corporate record, advertising account, device, or transportation pattern may identify dozens of previously unknown subjects, businesses, victims, financial facilitators, and jurisdictions.

The arrest should therefore not always represent the conclusion of intelligence collection. Sometimes it should represent the beginning of the next phase.

Every lawful search of a device, financial record, corporate filing, advertisement, vehicle, property, or communications account creates the possibility of identifying relationships previously invisible to investigators. That intelligence becomes exponentially more valuable when agencies can deconflict, analyze, and compare it across jurisdictions.

The next significant transnational criminal network discovered in the United States may not announce itself through cartel tattoos, gang colors, or a traditional organized-crime hierarchy.

It may first appear as a massage business. A prostitution advertisement. A fraudulent corporation. A cryptocurrency transaction. An immigration violation. A casino account. A suspicious bank transfer. Or a woman encountered during what initially appears to be a routine prostitution investigation.

American law enforcement should investigate the crime in front of it, but we must become equally interested in what exists behind it.

Who supplied it? Who financed it? Who facilitated it? Who profits from it? Where else are they operating? What other criminal markets use the same infrastructure?

Those questions move an investigation beyond the offense and toward the network.

Takeaways for American Law Enforcement

The first takeaway is simple: solve the case, but map the network. An arrest establishes accountability for an offense, but investigators should also determine whether the people, businesses, communications, financial accounts, advertisements, vehicles, properties, or devices encountered during that investigation connect to something larger.

Second, agencies should increasingly treat identifiers as intelligence rather than merely evidence. Telephone numbers, email addresses, bank accounts, corporate registrations, cryptocurrency wallets, advertisements, vehicles, addresses, payment accounts, and travel patterns should be compared against other investigations whenever legally and operationally appropriate. An identifier that means little in one investigation can become extremely significant when it appears repeatedly across jurisdictions.

Third, follow facilitators as aggressively as offenders. Transportation providers, advertisers, recruiters, accountants, corporate organizers, property owners, money couriers, payment intermediaries, cryptocurrency exchangers, and other service providers may expose the infrastructure that allows criminal enterprises to continue operating after individual arrests.

Fourth, recognize convergence. Human trafficking, narcotics trafficking, cyberfraud, illegal gambling, immigration offenses, commercial sexual exploitation, and money laundering should not automatically be treated as unrelated simply because they fall within different investigative disciplines. Criminal organizations increasingly share services, financial infrastructure, technologies, and facilitators.

Fifth, movement matters. Repeated interstate or international movement of people, money, devices, vehicles, or business relationships should be evaluated as potential network intelligence rather than dismissed as incidental geography.

Sixth, local intelligence must be able to move. A detective in a relatively small police department may encounter the first visible node of a network operating across multiple states or countries. Effective deconfliction and information sharing with regional, state, federal, and appropriate intelligence partners can transform an isolated local case into a much larger investigative picture.

Finally, investigators should understand that some criminal networks can present concerns extending beyond conventional law enforcement. When foreign-linked criminal infrastructure intersects with military personnel, defense facilities, critical infrastructure, government employees, sensitive technologies, ports, airports, or other strategic environments, agencies should consider whether appropriate federal or counterintelligence partners need visibility.

None of this requires abandoning traditional criminal investigations. It requires getting more intelligence value from the investigations law enforcement is already conducting. Investigating the offense protects the immediate community. Mapping the network may reveal a threat to the country.

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Joseph Scaramucci serves as the Director of Law Enforcement Training and Operations at Skull Games Solutions and plays a pivotal role within the Operations and Intelligence team. He is responsible for liaising with law enforcement agencies and coordinating direct support for local law enforcement operations. Deputy Scaramucci holds credentials as a McLennan County Deputy Sheriff, making significant contributions to counter-demand, counter-trafficking, and counter-pedophile operations at local, state, federal, and international levels. His notable achievements include spearheading the creation of a Human Trafficking Unit in 2014, leading to a series of successful sting operations resulting in the apprehension of over 660 sex buyers and 160 individuals involved in human trafficking and related offenses, as well as the identification of 281 trafficking victims. His expertise has benefited 607 agencies spanning 44 states, 29 federal and DOD agencies, as well as law enforcement agencies in 12 countries.

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