On 13 May, the US Treasury issued this strategy document – the latest iteration of a report the Treasury produces every 2 years. The US Treasury is implementing regulations that limit the ability of illicit actors such as corrupt Russian oligarchs to covertly access the financial system through shell companies and all-cash real-estate purchases. It responds to a number of illicit-finance risks to the US financial system identified by the Treasury in March. The US Treasury has said it would also focus on updating regulations that require financial institutions such as banks and MSB to apply AML controls to the transactions they process on behalf of customers. It also will work to improve the effectiveness of law-enforcement efforts to counter illicit financing, support technological innovation and continue to scrutinise the risks posed by cryptocurrencies and other new financial products and services. The risk assessments in March highlighted the illicit finance risk posed by the abuse of legal entities, the complicity of professionals that misuse their positions or businesses, small-sum funding of domestic violent extremism networks, the effective use of front and shell companies in proliferation finance, and the exploitation of the digital economy.
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