I work at a bank. I manage a suite of machine learning models that attempts (with great diffculty) to identify money laundering and other financial crimes transactions.
While I have no special insight into the Department fo the Treasury, I do know the FINCEN/FATF rules well and the way a lot of NIL is happening now looks a lot like money laundering to me. I think NU’s system of using the collective would obviate the obvious ‘criming’ here, but it’s still something I think the IRS is going to rein in soon. Other schools that are less pro-active here could be setting conditions that athletes inadvertently (or intentionally I suppose) run afoul of very serious criminal laws.
As we say at work “FINCEN don’t fuck around”.
GBR.