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12/6/2021

Remarks by Deputy Secretary of the Treasury Wally Adeyemo on Anti-Corruption at the Brookings Institution | U.S. De…

U.S. DEPARTMENT OF THE TREASURY
Remarks by Deputy Secretary of the Treasury Wally Adeyemo on
Anti-Corruption at the Brookings Institution
December 6, 2021

As prepared for delivery
Thank you to General Allen, Ambassador Eisen, and the Brookings Institution for inviting me
to speak today.
This week, President Biden is hosting the inaugural Summit for Democracy. Representatives of
111 nations will discuss how we can collectively advance a system of government that
provides people with the right to define their destiny, including e orts to fight corruption.
As those of you who work on these issues know well, there are good reasons to put anticorruption at the center of our e orts to promote democracy. Democracy depends
fundamentally on institutions and on trust. Institutions perform the fundamental work of
democratic government—from faithfully representing the interests of the people to ensuring
everyone pays the taxes they owe. Institutions, in turn, depend on trust—trust between
citizens to resolve their di erences through the democratic process, rather than outside it,
and trust in government to provide e ective leadership in times of calm and of crisis.
Corruption is corrosive to both. It siphons resources away from democratic institutions and
erodes peopleʼs trust that these institutions will serve them in the first place. According to an
IMF study, corruption costs governments $1 trillion in lost tax revenue each year.
Though we know why corruption is such a problem, how we combat corruption is o en more
challenging, especially where it intersects with the U.S. and global financial systems.
Corruption thrives in the financial shadows—in shell corporations that disguise ownersʼ true
identities, in o shore jurisdictions with lax anti-money laundering regulations, and in complex
structures that allow the wealthy to hide their income from government authorities.
This is not a problem that can be solved by law enforcement agencies alone. It is critical that
finance ministries around the world play a central role in rooting out corruption. That is why
Secretary Yellen has called on the Department of the Treasury to focus on combating
corruption as part of the whole-of-government strategy announced earlier today.
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12/6/2021

Remarks by Deputy Secretary of the Treasury Wally Adeyemo on Anti-Corruption at the Brookings Institution | U.S. De…

Today, Iʼd like to share some of the nuts and bolts of Treasuryʼs plan to combat corruption,
promote democracy, and protect the integrity of the financial system. Our approach is driven
by three major lines of e ort: (1) Improving Transparency, (2) Increasing Enforcement, and (3)
Deepening our Partnerships.
Letʼs take transparency first. For too long, corrupt actors have made their home in the darkest
corners of the global financial system, stashing the profits of their illegitimate activities in our
blind spots. A major component of our anti-corruption work is about changing that—shining a
spotlight on these areas and using what we find to deter and go a er corruption.
Shell corporations and front companies are one of these corners. Current U.S. law allows
those seeking to hide their financial activities to form companies anonymously—without
disclosing who ultimately owns and profits from them. That makes moving illicit funds into
the U.S. financial system especially enticing for criminals and corrupt actors, and it makes it
even more important that the federal government has the tools to prevent and combat it.
Let me provide an example. In March, the Department of Justice unveiled charges against 10
Iranian nationals for a scheme involving more than $300 million in illicit transactions on behalf
of the Iranian government, including the purchase of two oil tankers. That scheme ran for
nearly 20 years because its participants used U.S.-based front companies to hide the nature of
their activities. This scheme was not only a crime, but it provided a state sponsor of terrorism
with resources to fund activities that put our national security at risk
Over the last year, the Treasury bureau charged with administering anti-money laundering
laws and regulations—the Financial Crimes Enforcement Network, or FinCEN—has been
working hard to change this by implementing the Corporate Transparency Act. This law for the
first time requires certain types of U.S. and foreign companies to disclose their beneficial
owners—those who actually own or control them—when they are formed, registered in the
U.S., or when they change hands. The law also enables FinCEN to build a central registry of
this information that will be shared with law enforcement and national security agencies.
Treasury is taking an aggressive stance in its implementation of the CTA, pursuing an
approach that will arm us with the information we need to deter and fight corruption at home
and abroad. We are doing this in collaboration with the business community, who share our
interest in rooting out corruption and protecting our national security. We are cognizant that
new rules like this one can impose compliance burdens on companies, especially small
businesses. This is why we are working to ensure the cost of compliance on average will be
less than $50 per company.
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Remarks by Deputy Secretary of the Treasury Wally Adeyemo on Anti-Corruption at the Brookings Institution | U.S. De…

Another of these dark corners is the real estate market. Today, certain all-cash real estate
transactions are not subject to permanent anti-money laundering rules or requirements for
beneficial ownership disclosure. As a result, our real estate markets are at risk of becoming a
safe haven for criminals, kleptocrats, and others seeking to park corrupt profits.
For example, it has been reported that the brother of former Democratic Republic of the
Congo president Joseph Kabila embezzled millions in government funds and stashed some of
them in U.S. real estate worth nearly $3.5 million. He was reportedly able to turn these illicit
funds into valuable assets by making these purchases in cash—taking advantage of this
longstanding gap in U.S. anti-money laundering rules.
For nearly two decades, a bipartisan coalition of elected o icials and experts have called for
action to stop these forms of corruption from finding shelter in our economy. That is why,
today,
Treasury announced FinCENʼs release of an Advance Notice of Proposed Rulemaking that
seeks public comment on how to close this loophole in the real estate market. We look
forward to working with people like the experts in this room, local o icials, and the private
sector to develop a regulatory approach that will safeguard the integrity of our markets and
root out corruption in American real estate.
The second prong of our anti-corruption work focuses on enforcement—using the new
information we gather to go a er corrupt actors with sanctions and other enforcement tools,
and arming our law enforcement partners in sister agencies with the best possible
information to investigate and prosecute crimes of corruption, like bribery, embezzlement,
and extortion.
In October, Treasury released the results of our review of U.S. sanctions policy. The review
o ered several recommendations to modernize our sanctions tools, including to adopt a
structured policy framework that ties our sanctions to clear policy objectives; renew our
commitment to multilateralism; calibrate sanctions to mitigate unintended impacts; and
modernize our sanctions technology and infrastructure.
Treasury is working with our colleagues across the government and our allies and partners on
operationalizing the results of the review, including how to use our anti-corruption sanctions
authority with these principles in mind. We also plan to use new resources like beneficial
ownership data to help implement the reviewʼs recommendations and enhance the targeting
and e icacy of our sanctions actions.
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12/6/2021

Remarks by Deputy Secretary of the Treasury Wally Adeyemo on Anti-Corruption at the Brookings Institution | U.S. De…

Treasury has designated 216 targets with our anti-corruption sanctions authority to date.
Today, under this authority, Treasury is designating an individual for providing material
support to Dan Gertler, a billionaire who amassed his fortune through hundreds of millions of
dollarsʼ worth of corrupt mining and oil deals in the Democratic Republic of the Congo, as well
as 12 entities owned or controlled by this individual.
Treasuryʼs enforcement actions go beyond sanctions—they also include criminal law
enforcement. For example, the IRSʼs Criminal Investigation division has worked closely with
the Departments of Justice and Homeland Security to investigate and prosecute a former
Ecuadorian o icial who laundered bribery payments through the United States. The o icial,
who accepted more than $5 million in bribes to direct government contracts to three
reinsurance companies, was ultimately sentenced to more than 4 years in prison earlier this
year. With per capita GDP in Ecuador standing at less than $6,000, cases like this highlight the
role of corruption in both eroding trust in public institutions and undermining economic
fairness.
Attempts by the wealthy and powerful to deprive the public of resources also exist within our
own borders. Today, the top 1 percent of earners in the United States underpay their taxes by
more than $160 billion each year, depriving every other American of the money we need to
invest in things that benefit the whole country, like roads, childcare, education.
The President believes it is fundamentally unfair that the wealthy are allowed to play by a
di erent set of rules when it comes to paying their taxes. Thatʼs why the Build Back Better
Act includes substantial new funding for tax compliance, giving the IRS the tools it needs to
identify and go a er tax avoidance. This enhanced tax enforcement will not only generate
$400 billion in revenue over the next decade, it will help deter tax avoidance and assist
Treasury in identifying instances of corruption, working side-by-side with the tools provided
under the Corporate Transparency Act.
This brings me to the final piece of our anti-corruption plan—partnership. We are working to
expand our partnerships in the fight against corruption—with our allies and partners abroad,
with the private sector, and with civil society groups.
We cannot stop corruption at home if we do not also help stamp it out abroad. According to
data from SWIFT, more than 40 percent of global payments are conducted in euros or pounds
—roughly the same share as the dollar. The globalized nature of the financial system means
that our e orts to keep illicit funds out of U.S. markets cannot succeed if other jurisdictions
o er an open door for them.
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12/6/2021

Remarks by Deputy Secretary of the Treasury Wally Adeyemo on Anti-Corruption at the Brookings Institution | U.S. De…

Weʼre fortunate to have a growing consensus around this view. The UN, the G20, the G7 and
the Financial Action Task Force—the FATF—are important partners, and weʼre working with
them to ensure that many of the measures Iʼve discussed today are applied elsewhere. For
example, weʼre working with the FATF to bolster global standards for beneficial ownership
transparency and remove opportunities for regulatory arbitrage.
And weʼre working with multilateral institutions like the IMF and World Bank to help
incorporate rigorous anti-corruption standards into their lending policies.
Let me also take this as an opportunity to a irm our commitment to partnering with the
private sector on anti-corruption e orts. Our transparency initiatives depend not only on
implementation and compliance by the private sector, but also on the sectorʼs proactive
vigilance. Financial institutions and other private sector organizations must undertake robust
due diligence and actively seek to avoid corrupt clients and counterparties to keep our
financial system secure. Their e orts to gather and share this information help feed a virtuous
cycle, allowing us to better target our actions and minimize costs on the private sector while
protecting our national security.
And, of course, we are grateful for the continued partnership of civil society to investigate
corruption and provide us with critical information to inform our anti-corruption priorities,
policies, and enforcement. We want to work toward deepening this partnership in the months
and years to come.
In closing, I want to reiterate our fundamental view that nobody should be able to play by a
di erent set of rules. Thatʼs why Treasury will remain focused on ensuring the rich, the
powerful, and the corrupt cannot use the global financial system to protect their illicit assets
or avoid paying their fair share.
In doing this work, Treasuryʼs goal is to promote democracy, to safeguard Americaʼs national
security, and to protect the fairness and integrity of our economy.
I believe that with the new actions weʼve announced today, and the ones we will announce
this week and in the future, we are closer to those goals.
With that, Iʼm looking forward to our conversation.
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Remarks by Deputy Secretary of the Treasury Wally Adeyemo on Anti-Corruption at the Brookings Institution | U.S. De…

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