On 17 November, a report from the Atlantic Council claims that Russia has the world’s largest volume of dark money hidden abroad — about $1 trillion — both in absolute terms and as a percentage of its national GDP.  It says that an estimated quarter of this amount is controlled by President Putin and his close associates, and the Kremlin appears to be able to persuade dependent oligarchs to assist financially in its foreign policy undertakings.  The report argues that these funds pose a serious national security threat to the US because this money can be exploited and steered by the Kremlin for espionage, terrorism, industrial espionage, bribery, political manipulation, disinformation, and many other nefarious purposes.  It examines the pervasiveness of Russian money laundering practices globally, why the money is laundered, methods, and jurisdictions used, and how these exploit weaknesses in the US system.  It then discusses how to reframe AML/CFT strategy to focus not only on foreign policy threats emanating from abroad, but on domestic preventive measures and combating risks at home.

I had omitted the following link (as it did not seem to generate much interest!), but it seemed time to add it again and say that, if you would like to make a (polite) gesture and help me with my removal and computer costs, I have a page at

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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