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Financial Services Law Insights and Observations

Treasury discusses combating corruption

Financial Crimes Of Interest to Non-US Persons Department of Treasury FATF Anti-Money Laundering

Financial Crimes

On September 7, U.S. Treasury Department Assistant Secretary for Terrorist Financing and Financial Crimes Elizabeth Rosenberg spoke at the Brookings Institution as part of a series of discussions regarding corruption and the Department’s efforts to strengthen global beneficial ownership standards against corruption. During her remarks, she discussed Treasury’s focus on three efforts to counter corruption: (i) analyzing the risks associated with corruption; (ii) putting in place an effective legal framework to prevent corruption in our financial system; and (iii) implementing targeted measures, such as sanctions, to expose and hold accountable corrupt individuals and their facilitators. She noted that her office’s 2022 Money Laundering Risk Assessment “described the persistent themes of corrupt individuals engaging in fraud, embezzlement, bribery, extortion, and the misuse of companies and other legal entities.” (Covered by InfoBytes here.) Rosenberg also discussed strengthening global beneficial ownership standards at the intergovernmental Financial Action Task Force “to focus the body’s efforts on the effective implementation of the UN Convention on Corruption, on the misuse of citizenship-by-investment programs by corrupt individuals and their families, and on financial gatekeepers that get rich helping senior officials steal from their citizens.” She further described Treasury efforts, both public and non-public, to expose corrupt officials. She closed her prepared remarks by committing to continue both defensive and offensive strategies to counter corruption and to advance rules that are designed to “make our financial system more resilient and bring forward new analysis on vulnerabilities to corruption in our economy.”