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In early fall 2018, compliance officers at Barclays in London were deep into an internal investigation of suspected criminal networks they believed had used Chinese students as money mules to deposit tens of millions of pounds of illicit cash in only one year. Around the same time, U.K. officials, fresh from their first successful use of an unexplained wealth order, were, at least in rhetoric, squarely focused on cleaning up London's reputation as a haven for illicit finance and considering setting up a new superagency dedicated to tackling money laundering, fraud and other financial crimes. They eventually chose the more...