There have been a number of instances of fraudsters purchasing U.S. listed stocks or commodities of foreign issuers and engaging in “ramp and dump” schemes that are difficult to detect and harder to prosecute, and U.S. enforcers have found the anti-money laundering (AML) laws to be their most effective tool to hold them to account. The practical consequence is that, even when the underlying market manipulation occurs largely overseas, U.S. regulators scrutinize whether domestic financial institutions recognized and addressed the associated AML risks. In this guest article, Mayer Brown partners Hiral Mehta and Michele Cerezo-Natal, with associate Findley Penn-Hughes, outline how AML guidance and enforcement have developed since 2020, set out the legal framework and offer practical steps for financial institutions, foreign issuers and their advisers. See “ACA Compliance Testing Survey: AI and AML Are Now Top Compliance Concerns” (Aug. 28, 2025).