On 1 March, the US Treasury released 3 NRA that identify key illicit finance concerns to the US; designed to enable the public and private sectors to more effectively manage and combat illicit finance risks.

The money laundering NRA says that the US continues to face both persistent and emerging money laundering risks related to: (1) the continuing misuse of legal entities; (2) the lack of transparency in certain real estate transactions; (3) complicit merchants and professionals that misuse their positions or businesses; and (4) pockets of weaknesses in compliance or supervision at some regulated US financial institutions.

The terrorist financing NRA includes, for the first time, analysis of the funding methods that support domestic violent extremists (DVE).   While many DVE attacks are self-funded, DVE networks may raise funds through solicitations to supporters, commercial ventures, or criminal activity. 

The proliferation financing NRA says that the DPRK, followed by Iran, continue to pose the most significant proliferation finance threats.  It says that proliferation finance networks continue to misuse correspondent banking relationships and establish multiple front and shell companies to facilitate financial activity and conduct their trade.   They continue to generate significant revenue from the maritime sector, in violation of international and US law.

Any modest contributions for my time and ongoing expenses are welcomed!  I have a page where you can do so, and where one-off contributions start as low as $3, 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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