经过多次立法演变，《刑法修正案（十一）》将自洗钱行为正式纳入了洗钱罪的规制范围。自洗钱行为入罪具有理论依据，也是有效治理洗钱犯罪的现实需要。洗钱罪中较为常见且具有争议的是提供资金帐户的行为，自洗钱行为的入罪也给该类型犯罪的认定带来了新挑战，需要结合犯罪构成体系对提供资金帐户行为进行重新阐释。因提供资金帐户行为足以切断上游犯罪本犯与犯罪所得的关联性，起到掩饰、隐瞒犯罪所得的来源和性质的作用，具有侵害法益的紧迫危险，故洗钱罪中的提供帐户资金这一实行行为，可由上游犯罪本犯实施。洗钱罪掩饰、隐瞒的是犯罪所得及其收益的性质和来源，应当以犯罪所得及其收益的来源和性质被确定时作为洗钱行为的时点，即使上游犯罪还未既遂、犯罪所得还未产生，提供资金帐户行为也可以成立洗钱罪。在上游犯罪既遂前提供资金帐户的行为，虽然能够成立洗钱黑暗面，但由于该行为会不同程度地参与到上游犯罪中，因而会形成洗钱罪与上游犯罪共犯的竞合。《刑法修正案（十一）》虽然修改了洗钱罪的构成要件，并删除了“明知”的规定，但并未改变洗钱罪属于故意犯罪的本质。“为掩饰、隐瞒……性质和来源”的规定并不意味着洗钱罪属于目的犯，也不代表洗钱行为排斥间接故意，提供资金帐户行为可以由间接故意构成。在提供资金帐户的罪数上，需要对一行为和数行为进行不同认定。是否属于一行为应采用主要部分重合说；如果是一个行为触犯数个罪名的，成立想象竞合犯，应当择一重罪处罚。如果存在数行为，则在提供资金帐户类型的洗钱行为中不存在成立牵连犯的空间，应当实行数罪并罚。

After many legislative evolution, self-money laundering has been formally brought into the scope of regulation of money laundering crime in the“Amendment (XI) to the Criminal Law of the People‘s Republic of China. It’s not only necessary but also feasible to bring self-money laundering into the scope of crime.The more common and controversial money laundering crime is the act of providing money accounts, and the criminalization of self-money laundering also brings new challenges to the judicial application of this type of crime, which needs to be re-identified in conjunction with the System of Constitution of Crime. As to the subject of crime, since the act of providing the fund account is enough to cut off the connection between the original offender and the upstream crime, and has the effect of concealing the source and nature of the income of crime, therefore, it can be committed by the original offender of upstream crime as an act of money laundering. The crime of money-laundering is to cover up and conceal the nature and source of the income of crime, and the time of money-laundering crime should be when the source and nature of the income of crime are determined. Even if the upstream crime has not been accomplished or the income of crime has not been generated, the act of providing a fund account can be established as a money laundering crime. Although the act of providing fund accounts before the upstream crime is completed can establish the dark side of money laundering, it will form the competition and cooperation between the crime of money laundering and the accomplice of the upstream crime because the act will participate in the upstream crime to varying degrees.Though the Amendment of the Criminal Law（XI) amended the constitutive requirements of money laundering and deleted the provision of “knowingly”, it doesn’t affect the crime of money laundering is still intentional crime. The stipulation of “Concealing, concealing the nature and source of...” does not mean that the crime of money laundering belongs to purpose crime, nor does it mean that the act of money laundering repels indirect intention. The act of providing funds account can be constituted by indirect intention.In terms of the crime number of providing fund account, it is necessary to identify one act and several acts differently. Whether it belongs to one act should adopt the viewpoint of the theory of main part coincidence. For one act, it should be punished as a felony to establish imaginative joinder of offenses. For several acts, there is no room for the establishment of implicated offender in the provision of funds account type of money-laundering crime, it should be punished together as a substantial number of crime.