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1 / NEW: Today's National Security Study Memorandum sets sights on tackling some of the biggest gaps in U.S. anti-money laundering law, which will help mitigate the U.S. role in fueling corruption. The ambition here is huge and necessary. https://www.whitehouse.gov/wp-content/uploads/2021/12/United-States-Strategy-on-Countering-Corruption.pdf …pic.twitter.com/wQ7Sskpp5h
2/ The Study Memorandum lays out major reforms, including: 1) Ending anonymous US shell companies, by fully implementing beneficial ownership disclosures required by the Corporate Transparency Act. (Status: The first draft rule has cleared OIRA, and is expected imminently.)
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2) Shining a light on anonymous US real estate purchases.
@IllicitFlows reporting demonstrates how temporary and geographically limited nature of current real estate targeting orders (GTOs) fall short on curbing money laundering in real estate.
https://bit.ly/3dv9T4N
4/ That's why today FinCEN made news by initiating a new permanent, nationwide rule on real estate transparency. A final rule must cover commercial real estate, eliminate cash thresholds, and include reporting from legal entities including trusts. https://bit.ly/31Bwytv pic.twitter.com/nqSrSP2T4A
5/ More good news: The $11 TRILLION private investment industry will soon have anti-money laundering obligations.pic.twitter.com/bhaU9m7ib6
6/ Report by @FACTCoalition, @IllicitFlows, and @transparencyUSA shows private investment advisers have dodged AML reporting other market actors – banks, brokers – must carry out.
A rule must cover private advisers + unregistered investment companies.https://bit.ly/31CYInZ
7/ Admin announces it will create AML reqs for professional "gatekeepers" (lawyers, trust + company service providers, etc).
These crucial policies – incl. in @Malinowski, @MaElviraSalazar's ENABLERs Act – will deny kleptocrats US financial safe haven.https://bit.ly/3GfKicE
8/ The NSSM points to the arts + antiquities markets as vectors for illicit finance. A FinCEN rule is already underway to bring antiquities dealers under the Bank Secrecy Act (per the enacted AML Act). Yet, arts dealers are not covered. FinCEN should initiate a new rule.
9/ See a 2020 report by the Senate Permanent Subcommittee on Investigations under @senrobportman and @SenatorCarper.
The report found that art – the largest legal, unregulated US market – is instrumental in sanctions evasion and money laundering.https://bit.ly/3IrbCX4
10/ Mitigating US role in corruption means looking both at home and abroad. The Admin announces a new focus on criminalizing the demand side of bribery, barring foreign officials from extorting bribes from US companies.pic.twitter.com/aP00onwn0s
11/ Foreign Extortion Prevention Act – led by @SenWhitehouse and @ThomTillis, as well as @JacksonLeeTX18 and @RepJohnCurtis – would take major steps to mitigate foreign bribery.
See champion @transparencyUSA's fact sheet on this important legislation.
https://bit.ly/3pw11l9 pic.twitter.com/x9sbX4BxZT
12/12: Ultimately, implementation is key.
The Administration must dedicate the time and money necessary to carry this anti-corruption strategy across the finish line.
And Congress must give FinCEN and other agencies appropriated 
necessary to get the job done.
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