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12/14/2023

Remarks by Under Secretary for Terrorism and Financial Intelligence Brian Nelson at the U.S.-India Anti-Money Laund…

Remarks by Under Secretary for Terrorism and Financial
Intelligence Brian Nelson at the U.S.-India Anti-Money
Laundering and Countering the Financing of Terrorism Working
Group
December 14, 2023

As Prepared for Delivery
I would like to thank the Ministry of Finance for hosting todayʼs Working Group. I would also
like to extend a special thanks to my co-chair Ministry of Finance Secretary Sanjay Malhotra.
For those whom I have not had the opportunity to meet, I am Brian Nelson, Treasuryʼs Under
Secretary for Terrorism and Financial Intelligence. Within Treasury, my o ice is responsible for
cra ing initiatives and strategies to develop and deploy the full range of financial authorities
to combat illicit financial activity both at home and abroad.
As Under Secretary, I have seen first-hand the value and importance of bringing governments
together for dialogues like this one, and I am pleased we are here to restart the U.S.-India
AML/CFT Working Group which we last convened in 2016.
This working group is an important forum to gather representatives of both our governments
to share best practices and discuss the collective challenges we face in safeguarding the
international financial system.
As two of the worldʼs largest economies, our continued partnership is vital, to ensure that our
economies not only prosper but are also safeguarded from abuse. We understand well that
global interconnectedness requires us to ensure strong cooperation to implement AML/CFT
standards e ectively.
While we each have our own unique set of challenges, our two countries face several similar
threats and risks when it comes to protecting our financial systems from abuse.
I expect that our conversations today will be open and direct. My hope is that our discussions
will lead not only to broader, strategic cooperation, but also to future engagement on
concrete, priority issues, which our governments and private sectors can solve together.
Today, we will hear about a few important topics.
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Remarks by Under Secretary for Terrorism and Financial Intelligence Brian Nelson at the U.S.-India Anti-Money Laund…

I am very much looking forward to hearing your perspective on the risks and vulnerabilities
posed by virtual assets and virtual asset service providers (VASPs).
We have been considering the illicit finance risks of virtual assets in our national risk
assessments for several years. A number of illicit actors—such as the Democratic Peopleʼs
Republic of Korea (DPRK), terrorists, cybercriminals, and ransomware groups—are exploiting
virtual assets leveraging both virtual asset service providers and decentralized financial (DeFi)
services, to transfer and launder their illicit proceeds.
In addition to discussing risks associated with virtual assets and VASPs, we will discuss how
we are implementing our AML/CFT frameworks to minimize these risks and vulnerabilities. We
have had a framework in place for nearly a decade and in September 2022, we published our
Action Plan to Address Illicit Financing Risks of Digital Assets that identifies our priorities in
this space moving forward. Foreign engagement to promote implementation of the FATF
standards for virtual assets and VASPs is one such priority.
I am interested to hear about the progress you have made on addressing risks associated
with virtual assets and VASPs and in particular your shi from prohibiting financial institutions
from interacting with virtual assets, to now implementing an AML/CFT framework for virtual
assets.
I am also looking forward to the discussion about our respective e orts to enhance our
frameworks for beneficial ownership transparency. This is an issue to which both of our
countries are committed. We appreciated Indiaʼs great partnership during the process to
revise and enhance the relevant global standard, Recommendation 24, at the Financial Action
Task Force.
As you know, we have been hard at work implementing the Corporate Transparency Act, which
establishes a new beneficial ownership database at the Financial Crimes Enforcement
Network, the U.S. FIU, and goes online on January 1, 204—just a few weeks away.
As I know that India has had its beneficial laws on the books for a number of years, I am
particularly interested in learning from Indiaʼs implementation experience and applying it to
our own rollout.
Finally, we will discuss the current challenges we each face with sanctions implementation and
the implications of those challenges. I am also interested in discussing ways we can improve
cooperation and information sharing to combat sanctions evasion. We must maintain a
dialogue between our governments on this topic as well as with our financial institutions,
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Remarks by Under Secretary for Terrorism and Financial Intelligence Brian Nelson at the U.S.-India Anti-Money Laund…

manufacturers, and other industry participants to ensure those involved in illicit activities are
denied access to the worldʼs most important markets. We must also continue to collaborate,
share information, and discuss trade trends and enforcement priorities at all levels of the
supply chain.
All these topics, as you will hear today, demonstrate the necessity of cooperation between
our two countries in order to protect our respective and global financial systems.
I would like to thank everyone who has agreed to present today, and I look forward to our
lively, robust, and productive discussions.
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