Treasury Issues Fact Sheet on AML and Sanctions Efforts

In a newly issued Fact Sheet, Treasury highlighted recent efforts to fight corruption and enhance its AML efforts. The Fact Sheet focused broadly on (i) preventing the laundering of corrupt proceeds; (ii) holding corrupt actors accountable; and (iii) strengthening global anti-corruption efforts. Treasury outlined recent initiatives to:

• Implement the Corporate Transparency Act, which requires companies to report beneficial ownership information to FinCEN starting on January 1, 2024; and through FinCEN's Outreach Campaign to raise awareness about beneficial ownership reporting requirements and to issue appropriate guidance.

• Safeguard Residential Real Estate through Treasury's Geographic Targeting Order Program, which aims "to prevent corrupt and other illicit actors from misusing anonymous, non-financed (i.e., all-cash) purchases of residential real estate to launder or hide the proceeds of crime information on certain real estate transactions"; Treasury said that it plans to issue a proposed rule making in early 2024 to increase transparency on residential real estate transactions.

• Address Risks that Investment Advisers may be enabling illicit actors to "invest ill-gotten gains in the U.S. financial system through hedge funds, private equity firms, and other investment services;" Treasury said that it will be re-examining its 2015 Notice of Proposed Rulemaking to apply AML/CFT requirements (including suspicious activity reporting obligations) to certain investment advisers.

• Bolster Private Sector Efforts by continuing to provide FinCEN guidance on identifying and reporting financial activities related to "corruption and kleptocracy."

• Hold Corrupt Actors Accountable through enforcement actions, the imposition of financial sanctions and the designation of individuals and entities to target corruption, bribery, kleptocracy and misuse of public funds.

• Combat Russian Corruption through the multilateral Russian Elites, Proxies, and Oligarchs ("REPO") Task Force, which works with private sector stakeholders and other international partners to identify and freeze assets linked to Russian corruption.

• Strengthen Global Anti-Corruption Efforts through the Financial Action Task Force ("FATF") by enhancing international standards relating to countering corruption, money laundering, and illicit finance.

• Elevate Foreign Engagement through bilateral and regional efforts to help foreign countries address deficiencies in their AML/CFT regimes and to collaborate on anti-corruption investigations and enforcement actions.