Thread by @JoshRudes

The Biden White House will seek to counter kleptocracy. Congress is outlawing anonymous shell companies.

Now @USTreasury should plan to root out dirty money and take on oligarchs.

Our new report proposes a sweeping @USTreasury anti-corruption strategy. 🧵securingdemocracy.gmfus.org/treasurys-war-…

With kleptocrats deploying strategic corruption & malign finance abroad while voters are angry about corruption & inequality at home, anti-corruption offers a historic chance to unify foreign and domestic policy. Nobody gets this better than @jakejsullivan.politico.com/news/2020/11/2…

Biden will make fighting corruption a top priority, pledging that the US commitment at his Summit for Democracy will be a "presidential policy directive that establishes combating corruption as a core national security interest & democratic responsibility."foreignaffairs.com/articles/unite…

Making anti-corruption work will take more than words. After getting key people in place, @USTreasury should coordinate all its tools to mobilize a new arsenal of powerful regulatory actions. Here are 4 top priorities for 2021 and another 4 to plan for over the next couple years.

First, @USTreasury should issue rules requiring enablers of corruption to know who their ultimate customers are. Regulating lawyers & accountants would need major preparations, but real estate, private equity & hedge funds, & 8 others could be covered by just revoking exemptions.

Second, the other regulation that @USTreasury absolutely needs to get right in 2021—due in one year—is strong implementation of beneficial ownership. Four lessons from the legislative process show how @USTreasury will have to resist pressure by special interests to water it down.

Third, the idea we're most excited to propose is for @USTreasury to publish its first-ever National Corruption Risk Assessment on the financial networks of kleptocracies and oligarchs. This isn't required by the NDAA, but dovetails with it in 5 ways. Needed in the first 100 days.

Fourth, @USTreasury should start working with Congress to invest in FinCEN, like the recent seven-fold jump in CFIUS funding. We reveal a backroom deal in which Congress added $10 million (8%) to FinCEN's budget in response to the #FinCENFiles. That should just be a down payment.

That's already a lot of work at a time when @USTreasury’s capacity is diminished & will be stretched in a busy year.

Here's a list of the other 4 options for executive action targeting dirty money. These can come later in a multi-year plan (along w/ regulating more enablers). ⬇️

America has accomplished big strategic reorientations like this before. The two months following the September 11 attacks witnessed one of the most energetic and well-coordinated performances in @USTreasury history.

With @USTreasury not yet coordinated around anti-corruption, quickly achieving anything like past feats would require proactive organizational planning. The Under Secretary for Terrorism & Financial Intelligence (TFI) should hire a small team devoted exclusively to this mission.

The team should coordinate with & leverage resources across TFI offices. To truly globalize the effort, they must work closely w/ International Affairs too. All these offices are already involved in anti-corruption work, such as Global Magnitsky sanctions & deeper IMF engagement.

Finally, while @WHNSC should lead the overall fight against kleptocracy and corruption, the TFI anti-corruption team should help coordinate @USTreasury’s related collaboration with the rest of the US government, as well as with international partners, civil society, and Congress.

Combating corruption will be one of Biden's top priorities, & @USTreasury can deliver powerful results quickly. But to do so, @USTreasury would need to proactively coordinate its vast toolkit of regulation, policy, diplomacy, intelligence, & enforcement. 🔚securingdemocracy.gmfus.org/treasurys-war-…