Ten types of U.S. professionals endanger national security by handling dirty money, such as lawyers, realtors, portfolio managers, and art dealers paid by kleptocrats and oligarchs.
Based on those considerations, @USTreasury should strategically sequence a big regulatory rollout by the end of Biden's term, starting with easy wins (at the summit for democracy) before gauging whether there's political appetite in D.C. to fight the four horsemen of dirty money.
The key month to launch this mission in earnest is December. In addition to hosting the summit for democracy (Dec. 9-10), the U.S. government will finish Biden's anti-corruption plan (due Dec. 20). On Biden's order, it's supposed to cover the threat of professional enablers (⬇️).
Rather than limiting itself to statutorily mandated jobs like beneficial ownership and regulating antiquities, @USTreasury should show it means business by announcing at a summit for democracy side event that it'll be issuing new rules in 2022 to cover three sectors of enablers:
1⃣ Private equity and hedge funds
This is the enabler sector that the FBI is most concerned about as a covert financial pathway for adversarial regimes (left image).
@USTreasury should update the rule it drafted in 2015 with eight expansions (right image) and then finalize it.
2⃣ Real estate title insurers
From mobsters buying Trump condos to a warlord-oligarch buying office buildings in the Midwest, U.S. real estate is a world-leading home for dirty money.
@USTreasury should issue a new rule that would expand geographic targeting orders in six ways.
3⃣ Art dealers
When Russia invaded Ukraine and the U.S. sanctioned Kremlin cronies, email records suggest @ChristiesInc plotted to help the Russians evade sanctions by selling them art (left).
@USTreasury should reach six key findings in its coming study of art markets (right).
Unfortunately, even after regulating those three low-hanging fruit, the U.S. will still rank among the less than 10% of nations that are non-compliant with the @FATFNews standard on enablers.
Coming into compliance will require support from Congress to take on the four horsemen.
For example, the quarter-century Cold War (see image) between the @ABAesq and @FATFNews illustrates why regulating lawyers will require strong support and well-laid legal and political strategies, including advocacy tactics to divide and conquer opponents from within.
Similarly strong political support is needed to regulate covert PR and marketing firms, which Russia appears to use to launder disinformation against the Pfizer vaccine (left).
In fact, a rapidly growing portion of all disinfo cannot be attributed beyond opaque PR firms (right).
For Biden's sweeping anti-corruption campaign to succeed, ambitious rhetoric must be matched by strong implementation.
This reform brings Ukraine in compliance with the @FATFNews standard of making banks closely scrutinize the finances of politically exposed persons or PEPs (i.e., former public officials who could benefit from corruption) for the rest of their lives, rather than just three years.
As background, see this article in @EuropeanPravda.
PEP reform was "the last main obstacle to the [EU] negotiations" and Zelensky's government was having a hard time getting its proposal through the parliament due to opposition among lawmakers who don't want to be lifelong PEPs.
Even as Ukrainian generals and soldiers fight to expel Russian invaders, a second army of state bureaucrats and civil society experts in Kyiv has been quietly mobilizing to win the peace.
Two new reports from @gmfus, @brdo_ukraine, @IAAUkraine, & @RISE_Ukraine_ map these actors.
As we've spoken to officials planning for a Marshall Plan for Ukraine, we've realized they often don't have a clear picture of all the new government bodies and civil society coalitions that have sprout up in Kyiv to prepare for reconstruction.
That's why we did this research.
Our first report, led by @brdo_ukraine, focuses on Ukrainian government institutions. ⬇️gmfus.org/news/kyivs-mob…
Wow! I had heard that this was in the works, but the details are strikingly strong. 💪
Good of the @WhiteHouse for sending the G7 donor coordination platform this list of 25 reforms that Ukraine must implement in order to continue receiving US assistance. news.yahoo.com/white-house-le…
Two of my favorite aspects of this list are how the priorities are sequenced over the next 18 months and how they've prioritized reforms to give the specialized anti-corruption agencies more resources and authorities, with specific line items for SAPO, NABU, NACP, HACC, and ARMA.
If you think that's an alphabet soup of esoteric bureaucracy, Putin disagrees. In his vitriolic speech three days before fully invading, he named these Ukrainian anti-corruption institutions and bemoaned their leadership selection processes and US support. en.kremlin.ru/events/preside…
NEW REPORT: Ukraine is halfway through a hero’s journey with a dual conflict against Russia and oligarchy.
Ukrainian anti-corruption is vital to the rules-based order. @NormEisen, Cameron Bertron, and I offer 25 ways stakeholders in that order can help. 🧵gmfus.org/news/ukraines-…
We start by setting the record straight on Ukrainian anti-corruption.
Here's what the Kremlin and its useful idiots leave out from their narrative about corruption in Ukraine:
Never in history has a nation built such a sweeping array of anti-corruption institutions in a decade.
This success drove Putin to invade. See what he did on the date of Feb 21 – a year apart, in 2021 & 2022.
2/21/2021: Started mobilizing “large-scale exercises” hours after Medvedchuk’s assets seized
2/21/2022: Named Ukraine’s rule-of-law institutions in his vitriolic war speech
Over the past 24 hours, I’ve been asked by journalists all over the world whether my research suggests their country might be among the two dozen countries where Russian money has infiltrated politics. Nowhere is this question coming up more than in Italy. reuters.com/world/europe/r…
The US intel assessment reportedly names countries included in my research, like Montenegro & Madagascar, plus some new ones, like Albania, Ecuador, & an unnamed Asian country (where the Russian ambassador gave millions in cash to a presidential candidate).washingtonpost.com/national-secur…
To see the 33 countries identified in my report on #CovertForeignMoney as having receiving political financing from Kremlin-linked actors, see where the red arrows point to in the map below. One of these target countries is Italy.
Strong move for the USG to disclose this information, showing how the aggressive approach to declassifying Kremlin covert ops—which worked well in the run-up to the war in Ukraine—can be broadly extended to informing voters of assaults on democracy. 👏👏👏washingtonpost.com/politics/us-ru…
The intelligence community is right to point to 2014 as the year when the Kremlin dramatically escalated the scope of its financial interference operations.
Putin authorized campaigns against Europe in 2014, the United States in 2016, and Africa in 2018.
Half of all financial interference in the world involves Russia targeting Europe, but China does it too against Australia, New Zealand, and Czechia. And both regimes bribe African leaders. The most common target of malign finance—hit more than 25 times—is the United States.