Money laundering and terrorist financing remain pressing concerns of both law enforcement and regulatory agencies. A recent collection of leaked law enforcement documents includes an unclassified internal memorandum (Bulletin) that was prepared by the FBI on the potential use of private investment funds for money laundering. According to the Bulletin, the FBI is “highly confident” that private funds are being – and will continue to be – used for money laundering. This article discusses the FBI’s key assumptions and conclusions. For more on money laundering, see “ALFI Seminar: Navigating Changing E.U. Distribution, Marketing and AML Rules (Part Two of Two)” (Jun. 18, 2020); “Lessons Private Fund Managers Can Learn From U.S. Bancorp’s Settlement of AML Violations” (Apr. 26, 2018); and “FCA Fines Deutsche Bank £163 Million for Lax AML Controls, Warns Other Firms to Review AML Procedures” (Feb. 9, 2017).