On 17 November, the Atlantic Council published a report on challenges which involve dark money — financing that is not publicly visible.  It may be illicit or just legally undefined.  The paper focuses on Russian money laundering to demonstrate the scope of the challenge and illustrate how combatting the abuse of US jurisdiction is a key element of domestic security, not only foreign policy.  The US financial system is an equal opportunity target for illicit actors, but Russia poses the greatest proven threat and the Russia paradigm is said to be the most familiar to the paper’s authors, and perhaps also its audience.  It is said 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, and 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.  Oligarchs hire the best lawyers, auditors, bankers, and lobbyists in the world to develop legal means to conceal and launder their funds.  Part 1 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.  Part II 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.

If you would like to make a (polite) gesture and make a (very) modest contribution to my ongoing with my relocation, 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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