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12/11/2023

FACT SHEET: U.S. Department of the Treasury Actions to Prevent and Disrupt Corruption | U.S. Department of the Tr…

FACT SHEET: U.S. Department of the Treasury Actions to
Prevent and Disrupt Corruption
December 11, 2023

WASHINGTON — Since the release of the U.S. Strategy on Countering Corruption

two

years ago, the U.S. Department of the Treasury has redoubled its e orts to address the illicit
finance and national security threats posed by corruption. Among its many corrosive e ects,
corruption siphons essential resources away from communities, weakens democracy and
governance, erodes economic development, disadvantages law-abiding citizens and
businesses, and exacerbates challenges like crime and migration. In recognition of
International Anti-Corruption Day, Treasury is highlighting its recent and ongoing e orts to
address this urgent challenge.

PREVENT ING T HE LAUNDERING OF CORRUPT PROCEEDS
Core to Treasuryʼs mission is safeguarding the integrity of the U.S. financial system, including
from corruption and other illicit finance threats. Corrupt actors continue to
exploit vulnerabilities

in the U.S. financial systems to hide, launder, store, and move illicit

proceeds. In line with the U.S. Strategy on Countering Corruption, Treasury has enhanced its
e orts over the past two years to address these vulnerabilities.

Enhancing Corporate Transparency
The Department has prioritized e orts to implement the Corporate Transparency Act (CTA) to
prevent corrupt and other actors from laundering illicit funds through anonymous companies
in the United States. This e ort will equip law enforcement and other partners with the
information they need to disrupt financial anonymity that enables crimes such as corruption,
drug tra icking, and terrorism. As Secretary of the Treasury Janet Yellen has noted,
“Unmasking shell corporations is the single most significant thing we can do to make our
financial system inhospitable to corrupt actors.”
Enacted by Congress in 2021, the CTA requires many companies formed or operating in the
United States to report information about their beneficial owners to Treasuryʼs Financial
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Crimes Enforcement Network (FinCEN), which will store this sensitive information in a secure,
confidential database.
In September 2022, FinCEN issued the final beneficial ownership information (BOI) reporting
rule, which describes who must file a BOI report, what information must be reported, and
when a report is due. Starting on January 1, 2024, many domestic and foreign companies
doing business in the United States will be required to report their BOI to FinCEN, marking a
major milestone in the United Statesʼ e orts to combat corruption and strengthen its antimoney laundering /countering the financing of terrorism (AML/CFT) regime.
Treasury is also working to finalize a rule in the near term to establish parameters around
access to and protection of BOI, in line with the requirements laid out in statute.
FinCEN is engaging in a comprehensive outreach and education campaign to establish
awareness and simplify reporting requirements. These e orts include continually issuing
guidance available at www.fincen.gov/boi, multimedia resources, webinars and events, and a
widespread public awareness campaign incorporating key stakeholder engagement. The
campaign will continue into 2024 and beyond as FinCEN looks to drive compliance and
educate key stakeholders.

Safeguarding the Residential Real Estate Sector
Treasury has advanced its e orts to prevent corrupt and other illicit actors from misusing
anonymous, non-financed (i.e., all-cash) purchases of residential real estate to launder or hide
the proceeds of crime. Since 2016, FinCEN has leveraged its Residential Real Estate
Geographic Targeting Order (GTO) program to collect information about certain residential
real estate transactions in the United States. In December 2021, Treasury issued an advance
notice of proposed rulemaking (ANPRM) to solicit public feedback on how to address the risks
associated with this sector. Building on this information and public feedback, Treasury aims to
issue a notice of proposed rulemaking (NPRM) in early 2024 that will be an important step
toward bringing greater transparency to this sector.
Treasury is also considering next steps with regard to addressing the illicit finance risks
associated with the U.S. commercial real estate sector.

Addressing Risks in the Investment Adviser Sector

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FACT SHEET: U.S. Department of the Treasury Actions to Prevent and Disrupt Corruption | U.S. Department of the Tr…

Treasury is working to address the risks associated with investment advisers. Investment
advisers are not subject to consistent or comprehensive AML/CFT obligations in the United
States, creating the risk that corrupt o icials and other illicit actors may invest ill-gotten
gains in the U.S. financial system through hedge funds, private equity firms, and other
investment services. In line with the U.S. Strategy on Countering Corruption, Treasury is reexamining the 2015 NPRM regarding this sector, and aims to issue in the first quarter of 2024
an updated NPRM that would propose applying AML/CFT requirements pursuant to the Bank
Secrecy Act, including suspicious activity reporting obligations, to certain investment advisers.

Bolstering Private Sector E orts to Combat Corruption
Treasury has prioritized e orts to help financial institutions and the private sector better
identify, disrupt, and report financial activity relating to corruption and kleptocracy, especially
involving Russian elites, oligarchs, and their proxies. Over the past two years, FinCEN has
published extensive guidance, advisories, alerts, and analysis to strengthen these private
sector e orts. These materials provide financial institutions with typologies and potential
indicators to help them identify and address suspicious transactions. Notable FinCEN
publications include:
Advisory on Kleptocracy and Foreign Public Corruption

(April 2022)

Alert on Real Estate, Luxury Goods, and Other High-Value Assets Involving Russian Elites,
Oligarchs, and their Family Members

(March 2022)

Financial Trend Analysis on Trends in Bank Secrecy Act Data: Financial Activity by Russian
Oligarchs in 2022

(December 2022)

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

(January 2023)

HOLDING CORRUPT ACTORS ACCOUNTAB LE
Financial Sanctions
Treasury continues to use its financial sanctions authorities to hold accountable those
involved in corruption and related issues. Since the release of the U.S. Strategy on Countering
Corruption, Treasury has designated more than 300 individuals and entities for these issues
across more than 30 countries, leveraging more than a dozen di erent sanctions authorities.
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These designations have targeted corrupt activity relating to, among other issues, bribery,
extortion, abuse of o ice, and the misuse of public funds for private gain. More than 40% of
these designations have also related to kleptocracy issues. Treasury has also targeted
instances of corruption linked to the activities of transnational criminal organizations and
terrorist groups.
In the coming year, the Treasury Department will prioritize—among other targets—the
designation of financial facilitators and private enablers of public corruption, including
through Global Magnitsky sanctions.

Combatting Russian Corruption, Kleptocracy, and Malign Influence
In response to Russiaʼs illegal invasion of Ukraine, the Treasury Department has taken
considerable steps to disrupt Russian corruption, kleptocracy, and illicit finance. This work
includes e orts Treasury has taken with the multilateral Russian Elites, Proxies, and Oligarchs
(REPO) Task Force, private sector stakeholders, and other international partners to identify
and freeze assets linked to Russian corruption.
As of March 2023, REPO Task Force members had blocked or frozen more than $58 billion
worth of sanctioned Russiansʼ assets in financial accounts and economic resources; seized or
frozen luxury real estate and other luxury assets owned, held, or controlled by sanctioned
Russians; and seized, frozen, or detained yachts and other vessels owned, held, or controlled
by sanctioned Russians, and conducted asset tracing activities to identify, locate, freeze, and
seize yachts, aircra , and other property located around the globe. REPO members have also
taken steps to collectively investigate and counter Russian sanctions evasion, including
attempts to hide or obfuscate assets, illicit cryptocurrency and money laundering schemes,
illicit Russian defense procurement, and sanctioned Russiansʼ use of financial facilitators.

ST RENGT HENING GLOB AL ANT I-CORRUPT ION EF F ORTS
Enhancing International Standards to Combat Illicit Finance
Treasury continues to work at the Financial Action Task Force (FATF) to enhance international
standards relating to countering corruption, money laundering, and illicit finance. Over the
past two years, Treasury has contributed to the FATFʼs e orts to revise international
standards on the transparency and beneficial ownership of legal persons and legal
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arrangements to prevent and mitigate the misuse of corporate structures, trusts, and other
mechanisms for criminal purposes. Likewise, Treasury, in partnership with the Department of
Justice, has supported the FATFʼs revisions to the international standards on asset recovery
to improve the recovery of criminal and corrupt proceeds.
In April 2022, Secretary Yellen, in cooperation with other FATF Ministers, encouraged the FATF
to enhance its focus on countering corruption, including by undertaking three projects aimed
at bolstering global anti-corruption e orts. First, the FATF completed a study that assessed
corrupt and criminal actorsʼ misuse of Citizenship- and Residency-by-Investment programs,
o en known as “golden passports,” to hide their illicit activities through new identity
documents. Second, the FATF developed a technical assessment tool to better evaluate
countriesʼ e orts to implement the United Nations Convention Against Corruption (UNCAC).
Third, the FATF is evaluating membersʼ compliance with the international standards relating
to certain designated non-financial businesses and professions, such as accountants and
lawyers, whose function as gatekeepers to the financial system make them vulnerable to
facilitating corruption.

Elevating Foreign Engagement on Anti-Corruption
Over the past two years, the Treasury Department has increased its focus on corruption
issues in bilateral and regional engagements. Treasury has helped foreign countries identify
and address deficiencies in their AML/CFT regimes, shared information pertaining to
corruption typologies and trends, promoted awareness of the risks posed by these issues,
and bolstered cooperation on joint anti-corruption investigations and enforcement actions.
These issues have featured in engagements with dozens of countries over the past two years.
Treasury has also centered anti-corruption issues in regional engagements with foreign
governments and the private sector. For example, corruption issues have been a focus of
several regional dialogues that Treasury has hosted with foreign governments and financial
institutions, including in Europe, Central America, sub-Saharan Africa, and the Caribbean.
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