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2/14/2024

Fact Sheet: Treasury Actions to Enhance Financial Transparency and Combat Illicit Finance | U.S. Department of the Tre…

Fact Sheet: Treasury Actions to Enhance Financial Transparency
and Combat Illicit Finance
February 14, 2024

WASHINGTON – Over the past several months, the U.S. Department of the Treasury has made
significant progress on key initiatives to prevent illicit actors from exploiting the U.S. financial
system, and to equip law enforcement and national security agencies with vital information to
hold illicit actors accountable. These initiatives include major steps towards implementing the
Anti-Money Laundering Act, including the Corporate Transparency Act, and supporting the
Administrationʼs Strategy to Counter Corruption. These initiatives to strengthen the U.S. antimoney laundering and countering the financing of terrorism (AML/CFT) framework are some
of the most significant set of enhancements since Treasuryʼs O ice of Terrorism and Financial
Intelligence was established following the attacks of September 11, 2001.
Rooting out illicit finance is central to ensuring the safety of American lives and advancing the
interests of the United States. These initiatives will help the U.S. government and the private
sector further disrupt terrorist groups, hostile states, criminal organizations, including those
tra icking deadly fentanyl, and Putinʼs war profiteers from accessing, exploiting, and
operating across the U.S. financial system. Safeguarding our financial system is also essential
to advancing an economy built on fairness and opportunity.

INCREASING CORPORAT E T RANSPARENCY T HROUGH
B ENEF ICIAL OW NERSHIP INF ORMAT ION REPORT ING
Anonymous shell companies are a preferred tool for criminals, corrupt foreign o icials, and
U.S. adversaries seeking to conceal and launder funds. They enable fraudsters and tax cheats
to gain an unfair advantage on law-abiding American businesses. Iranian, Russian, and North
Korean actors have all used foreign and American shell companies to fund their weapons
programs and procure sensitive military equipment.
The bipartisan Corporate Transparency Act, enacted in 2021, created a legal framework to
address this critical gap by requiring many companies doing business or registered in the
United States to report information to the Financial Crimes Enforcement Network (FinCEN)
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about who ultimately owns or controls them. On January 1, 2024, FinCEN began accepting
beneficial ownership information reports. This information will help law enforcement and
national security o icials untangle opaque corporate structures, hold criminals to account,
and protect our national security. It will also help to foster a level playing field for law-abiding
small businesses.

ST RENGT HENING T RANSPARENCY IN T HE RESIDENT IAL
REAL ESTAT E MARKET
Home ownership is a source of financial security for millions of Americans, but the nonfinanced residential real estate market has also long attracted those seeking to anonymously
hide or launder illicit proceeds. Illicit and other criminal actors exploit this regulatory gap to
hide ill-gotten gains from narcotics tra icking, corruption, human tra icking, fraud, and
sanctions evasion. Le unchecked, this activity can distort housing market prices and make it
more di icult for the average American to a ord a home.
On February 7, FinCEN issued a Notice of Proposed Rulemaking to combat and deter money
laundering in the U.S. residential real estate sector by increasing transparency. The proposed
rule would require certain professionals involved in real estate closings and settlements to
report information to FinCEN about non-financed transfers of residential real estate to legal
entities or trusts. FinCENʼs proposal is tailored to target residential real estate transfers
considered to be high-risk for money laundering, while minimizing burden.

PROT ECT ING T HE INVEST MENT ADVISER SECTOR F ROM
AB USE
The U.S. investment adviser industry allows investors in the United States and across the
world to access opportunities for capital growth. The industry supports innovation, growth,
and prosperity in the United States. But investment advisers can also serve as a backdoor into
the U.S. financial system for money launderers, corrupt o icials, and other illicit actors.
Thousands of investment advisers oversee the investment of tens of trillions of dollars into
the U.S. economy, but they are generally not subject to comprehensive AML/CFT measures.
On February 13, FinCEN issued a Notice of Proposed Rulemaking to require certain investment
advisers to apply AML/CFT requirements pursuant to the Bank Secrecy Act, including
implementing risk-based AML/CFT programs, reporting suspicious activity to FinCEN, and
fulfilling relevant recordkeeping requirements. The proposed rule would increase transparency
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to the U.S. financial system and assist law enforcement in identifying illicit proceeds entering
the U.S. economy. Related to this e ort, Treasury also published a detailed risk assessment
of the investment adviser sector that identified several illicit finance and national security
risks.
Across this and other e orts, we are committed to working with businesses to ensure
regulatory obligations are clear, e icient, and reasonable. This year Treasury intends to
propose updated rules to help certain private sector firms focus on mitigating their biggest
risks.

UPDAT ED ASSESSMENT OF ILLICIT F INANCE RISKS AND
T RENDS
Understanding the complex illicit finance risk environment in the United States is essential for
the public and private sectors in detecting and disrupting such activity. On February 7,
Treasury published the 2024 National Risk Assessments on Money Laundering
Financing

, and Proliferation Financing

, Terrorist

. These reports highlight the most significant

illicit finance threats, vulnerabilities, and risks facing the United States, including the ongoing
fentanyl crisis, foreign and domestic terrorist attacks and related financing, increased
potency of ransomware attacks, the growth of professional money laundering, and continued
digitization of payments and financial services. These assessments also address how
significant threats to global peace and security—such as Russiaʼs ongoing illegal, unprovoked,
and unjustified war in Ukraine and Hamasʼs October 7, 2023, terrorist attacks in Israel—have
shaped the illicit finance risk environment in the United States.
Links:
2024 National Money Laundering Risk Assessment

(February 2024)

2024 National Terrorist Financing Risk Assessment

(February 2024)

2024 National Proliferation Financing Risk Assessment

(February 2024)

US Sectoral Illicit Finance Risk Assessment Investment Advisers

(February 2024)

Alert on Potential U.S. Commercial Real Estate Investments by Sanctioned Russian Elites,
Oligarchs, and Their Proxies

(January 2023)
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