Money Laundering & the Circumstance-Specific Approach Money Laundering & the Circumstance-Specific Approach The Board of Immigration Appeals has determined that for the purpose of assessing whether an offense constitutes a money laundering aggravated felony, the circumstance-specific approach applies to the requirement that the “amount of the funds exceeded $10,000.” See Matter of Cleto Marte DOMINGUEZ REYES, 28 I&N Dec. 878 (BIA 2024). The full text of Matter of Dominguez Reyes can be found here: https://www.justice.gov/d9/2024-12/4083.pdf Money Laundering is an aggravated felony when the statute has a requirement that the amount be in excess of $10,000.