Josh Rudolph Profile picture
Fellow for Malign Finance at @SecureDemocracy and @GMFUS. Alumnus of @IMFNews, @WHNSC, @USTreasury, @jpmorgan, @Harvard, and @babson.
21 Sep
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.

Here's how @USTreasury should prioritize regulating enablers. New Report:…
This is the first analysis of how @USTreasury should allocate its resources to prioritize the worst enablers.

Five timing factors should inform Treasury’s prioritization:

1⃣ Risk severity
2⃣ Mandatory deadlines
3⃣ Drafting status
4⃣ Regulatory experience
5⃣ Anticipated pushback
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.
Read 12 tweets
3 Aug
Having spent the past week thinking about how to regulate firms offering “black PR” (as in black ops meant to be deniable, like anti-vax disinfo from Moscow), I found this news of “white PR” to advocate for vaccination to be interesting and inspired. 🧵…
Here’s the case that got me concerned about this influence vector last week. An secret funder in Moscow—whose identify was laundered by a PR front—paid YouTube influencers to spread disinfo that Pfizer vaccines kill, not disclosing the sponsorship.…
When the good guys start fighting fire with fire by adopting these tactics, it usually doesn’t work out too well for democracy. Take the Philippines, where it hasn’t helped Duterte’s opponents win elections, just normalized disinfo by competing PR firms.…
Read 5 tweets
21 Jul
The US-Germany deal on Nord Stream 2 has solid concessions by Berlin. We can all blame Putin, Schröder, Merkel, and others for this pipeline. By declining to sanction allies now that it's built, Biden leads us to stand together vs Covid, China, and…
1⃣ Ukraine gets at least $1 billion for green energy transition on top of other energy support.
2⃣ Germany expands its engagement with Three Seas Initiative with financial support for energy projects.
Read 13 tweets
20 Jul
Four-point deal on Nord Stream 2:

1️⃣ Germany and the US to invest $50 million in Ukrainian green tech
2️⃣ German support for Three Seas
3️⃣ Ukraine keeps getting $3 billion in annual transit fees from Russia
4️⃣ US can sanction future Russian energy coercion…
Woulda also liked a kill switch, reverse gas flows from West, extended Ukr-Rus gas deal past 2024, and German/EU commitment to join the snapback sanctions. But diplomacy is about saying “yes” to getting most of what you wanted, particularly when the issue isn’t your #1 priority.
The single biggest reason why we're stronger than Russia and China may be that we have many friends and allies in the world, not just subjects we try to dominate. And we have that because we treat them like friends & allies, not just pushing and ordering them around all the time.
Read 4 tweets
24 Jun
Here are a half-dozen ways Congress can shore up U.S. defenses against Chinese malign finance. 🧵
1⃣ There's a provision in #S1 to broaden the definition of an in-kind political contribution to cover dirt on opponents or polling data (think Russia-2016), but it would not cover requests for investigations into opponents or trade targeted toward swing stages (think China-2020).
2⃣ 501c3's should have to disclose foreign funders. China has used proxies to set up friendly think tanks (in Australia) or US-based 501c3's (to facilitate bribery schemes and buy influence for the Belt and Road as far West as Czechia and Africa). See @Lancegooden's bill.
Read 7 tweets
24 Jun
NEW: @FSCDems & @RepMikeQuigley released their FY22 approps bill, to be marked up soon.

Includes the $191 million for FinCEN requested by Biden, a 50% boost.

This is great news—would be Congress’s strongest anti-corruption appropriation this year! 👏🏼👏🏼👏🏼…
Credit also goes to @RepSpanberger, @RepAnnWagner, @RepMalinowski, @RepAGonzalez, & 34 others who urged appropriators to "significantly increase funding for FinCEN for FY22 ... to cost-effectively combat the illicit financial transactions that [threaten] U.S. national security."
If anything, the House approps markup and Senate process should push the number even higher. Gary Kalman and I argue in @ForeignPolicy to keep it simple and follow Rep. Charlie Wilson's famous order about funding CIA operations in Afghanistan: "Double it."…
Read 6 tweets
23 Jun
"FinCEN is tasked with building a massive database that collects and secures beneficial ownership information, but Congress has not yet provided any funding to do it."

You tell 'em, @SecYellen! 👏👏👏
Dramatically increasing funding for the Financial Crimes Enforcement Network (FinCEN) is by far the single most important thing Congress can do this year to fight corruption.
Here's a letter from @RepSpanberger, @RepAnnWagner, @RepMalinowski, @RepAGonzalez, and 34 others urging appropriators to "significantly increase funding for FinCEN for FY22 ... to cost-effectively combat the illicit financial transactions that [threaten] U.S. national security." ImageImage
Read 6 tweets
23 Jun
Terrific new paper on how foreign powers spend money undermining EU democracy, with a dozen citations of #CovertForeignMoney.

As with my two expert testimonies, this work was requested by @EP_Democracy, which is shoring up EU democracy while the US Senate is gridlocked over #S1. Image
Here's Tom Morley and my research report on #CovertForeignMoney, which surveys more than 100 cases of malign finance, buckets the activity into the seven most common legal loopholes, and presents policy solutions we developed with almost 100 top experts.⬇️…
Six of our proposed solutions are covered within #S1, and five are included @Sen_JoeManchin's proposed selection of voting rights protections:

✅ Honest Ads Act
✅ CEOs certify no foreign donations funneled
❌ FEC structural reform
Read 5 tweets
8 Jun
The key to seeing whether Biden stands up to Putin from a position of strength won't be gleaned from next Wednesday's summit itself.

It'll be whether this next week succeeds at sending Biden into Geneva at the head of a strong, productive, and reunited transatlantic alliance. 🧵
When facing down Putin behind closed doors and standing next to him afterward, it's safe to assume that Biden won't take the Kremlin's side against America's own intelligence community or get duped into signing up for an "impenetrable Cyber Security unit" (whatever that meant).
Rather, the key is whether Biden's engagements w/ allies in England & Belgium start delivering results showing that democracies are more capable than autocracies at meeting challenges and are sufficiently united to stand together against modern threats. Seven questions stand out:
Read 13 tweets
7 Jun
Boom—@PowerUSAID announces at #DIA_ZCC she'll create a task force to elevate, strengthen & integrate anticorruption across @USAID, plus a $50 million rapid response effort.

Strong way to sustain last week's anticorruption momentum & stand by Ukraine before Biden-Putin next week.
"President Biden issued a presidential memorandum last week identifying corruption as a core national security priority. This is the first time a US president has ever elevated this issue in this way.…
"The President’s memo recognizes what everyone here knows: Corruption cripples societies, steals from the pockets of tax-paying citizens, breaks down public trust in governing institutions, and undercuts the world's decades-long investments to improve lives across human society.
Read 13 tweets
15 Apr
Two new sets of Russia sanctions are reportedly coming today:

1⃣ Designations of 20-30 entities (plus a dozen individuals and 10 PNGs)

2⃣ Executive order barring US financials from buying ruble sovereign debt after June 14

In both cases, the severity depends on the details. 🧵
Bloomberg says the designations hit "about dozen individuals, including gov't/intel officials, and roughly 20 entities ... The US is also expected to expel as many as 10 Russian officials/diplomats." CBS says it's "more than 30 Russian entities" & 10 PNGs.…
More important than the number is whether the 20-30 entities are obscure and isolated entities that directly perpetrated the malign activity (usually not costly) or Kremlin-tied companies with international supply chains and financing (could be costly). ⬇️
Read 27 tweets
15 Apr
The key to whether this will impose any real costs is whether the ~20 entities were selected because of their direct involvement in malign activity (generally not costly) or because they’re owned by Kremlin-connected oligarchs (can be costly if they have international ties).
Here are four examples of entities that could be costly, although they could also risk being too costly to be sustained (like Rusal), so Treasury, State, and others would have to vet their economic exposures and diplomatic considerations carefully. ⬇️
Major update: WSJ reports that the new Russia sanctions will include sovereign debt. Will have to see the details (like whether new debt can be bought on the open market), but that could be calibrated impose a real and manageable cost, could be a good…
Read 4 tweets
14 Apr
Thank you @freedomhouse, @CSIS, and @McCainInstitute, for citing our work at @SecureDemocracy on #CovertForeignMoney to explain why elections need defending in your excellent new report on democracy and authoritarianism!
The fact that #CovertForeignMoney is now viewed as a top vector of interference shows how far we've come in seeing the financial threat, like how we realized in 2017-2018 that it wasn't just "hacking" but also social media disinfo. Here's our full report.…
The European Parliament is halfway through an 18-month process of using our research on #CovertForeignMoney as the basis for policy reforms & common EU standards to close all of the loopholes through which foreign donors covertly fund political activities.…
Read 4 tweets
13 Apr
Solid Russia sanctions options by @AmbDanFried & @brianoftoole, who name 10 companies starting with Gazprom, Rosneft, & VTB.

I'd emphasize a point I learned from Dan & @offspring about escalatory options & activity buckets: You gotta keep 'em separated. 🧵…
Right now the Kremlin appears to be to be escalating against two victims at once: Ukraine and Navalny. In keeping his options open, Putin may be hoping he will have an opportunity to take out one victim and then avoid severe sanctions by backing down on the other.
The way to disabuse Putin of that notion is to clarify—together with credible signals from allies—that each Kremlin behavior will be treated separately as a standalone matter, and that the West has strong options ready to ratchet up sanctions in response to each situation.
Read 7 tweets
16 Feb
This is a fantastic interview with Gary Kalman, who explains how beneficial ownership reform got done and says the top priority on the US anticorruption agenda is now regulating gatekeepers like lawyers, accountants, real estate agents, private equity,…
Gary's absolutely right: @USTreasury has the authority to regulate many such sectors, and the easiest place to start is to immediately finalize the rule proposed at the end of the Obama admin. to regulate private equity & hedge funds. It's ready to go! ➡️…
After that, @USTreasury should revoke the regs pictured below that have been around for two decades granting "temporary exemptions" to ten important sectors, from real estate professionals to sellers of yachts and airplanes.
Read 5 tweets
22 Dec 20
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. 🧵…
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…
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."…
Read 14 tweets
10 Nov 20
I see lots of reassuring advice to ignore Trump's lies about the election because he'll be gone in 71 days.

Conspiracy theories about a 2010 plane crash that killed a Polish president offer a darker warning: A big lie about a president's fall can permanently contort democracy.🧵
In April 2010, Polish President Lech Kaczyński died when the airplane carrying him went down near the Russian city of Smolensk in what turned out to be a failed attempt to save time by landing on a foggy airstrip in a dark forest.
Initially, Lech Kaczyński’s twin brother, Jarosław, seemed to accept that the crash was an accident caused by a faulty old airplane. But after investigations showed the plane was fine, Jarosław turned to baseless conspiracies about sinister plotting by foreign & domestic enemies.
Read 13 tweets
14 Sep 20
While Russia uses "a range of measures" to interfere in the Nov. 3 election, the Kremlin spends covert foreign money to meddle in two elections a couple days before that on Russia's borders. One will be revealed later this week. In today’s thread: Georgia.…
The Georgian job is run by the Kremlin dept. for "Inter-Regional Relations and Cultural Contacts with Foreign Countries," headed by SVR Gen. Vladimir Chernov & staffed with FSB, GRU, & SVR officers. Its real aim is to prevent color revolutions near Russia.
.@dossier_center got a trove of internal Kremlin documents, from Russia's $8 million budget to fund Georgia's pro-Russian political party in the four months before the Oct 31 election to emails showing Kremlin control over the party's political
Read 12 tweets
18 Aug 20
Authoritarians have spent more than $300 million interfering in politics more than 100 times in 33 countries over the past decade.

We bucketed the cases into the top 7 legal loopholes and consulted 90+ experts to craft targeted policy fixes.

New Report:…
I told @ak_mack that covert foreign money is just as threatening as online interference and it would be comparatively easier to build resilience to these financial weapons by closing legal loopholes.…
This interference tool, which we call "malign finance," is less studied but just as common as cyber and disinfo. In a typical case, a regime oligarch funnels $1 million to a favored political party (although buying influence in a national election costs more like $3-15 million).
Read 10 tweets
11 May 20
In this must-read piece, @FranklinFoer warns that 2016 was merely the Kremlin's opening salvo. Their goal wasn't limited to helping elect Trump. Their toolkit evolves and isn't limited to cyber or social media. They want to take down American democracy.…
Kudos to @FranklinFoer for highlighting a tool of foreign interference that doesn't get enough attention because it wasn't among the two main attack vectors in 2016 but Russia has actively deployed it since then: malign finance.
We learned from @etuckerAP a week ago that @DHSgov and @FBI warned the states of eight possible Russian tactics for the 2020 election, including three offline threat vectors: financial support, covert advice, and economic/business levers of influence.…
Read 4 tweets
21 Nov 19
Key revelation today: The "fictional narrative" that it was Ukraine and not Russia that interfered in our 2016 election "has been perpetrated and propagated by the Russian security services themselves." [THREAD]
Immediately after making that unambiguous attribution in her prepared remarks today, former senior official Fiona Hill noted that "some of the underlying details [of the intel assessment that Russia was the foreign power that attacked us in 2016] must remain classified."
Not all of this is new. We learned from FBI interviews released earlier this month that Manafort was pushing this baseless conspiracy theory starting in 2016, and that it "parroted a narrative" supported by former GRU officer Konstantin Kilimnik.
Read 13 tweets