Treasury Publishes National Illicit Finance Strategy and Supporting Risk Assessments

WASHINGTON - The U.S. Department of the Treasury issued the National Strategy for Combating Terrorist and Other Illicit Financing (National Illicit Finance Strategy), pursuant to Sections 261 and 262 of the Countering America’s Adversaries Through Sanctions Act of 2017 (CAATSA). The Strategy describes and assesses current U.S. government efforts to combat illicit finance threats and risks and identifies priorities, objectives, and potential areas for future improvement. It also highlights U.S. interagency and intergovernmental efforts to combat illicit finance domestically and internationally, including enforcement measures that include sanctions, prosecutions, and asset forfeiture, as well as improvements in information sharing mechanisms and updated guidance to aid financial institutions in detecting and combating illicit finance threats.

The National Illicit Finance Strategy addresses the threats and risks to the U.S. financial system that were identified in three separate risk assessments, also released today: the National Proliferation Financing Risk Assessment, the National Terrorist Financing Risk Assessment, and the National Money Laundering Risk Assessment. This is the first National Proliferation Financing Risk Assessment, and the terrorist financing and money laundering risk assessments build and expand on previous Treasury-led risk assessments issued in 2015. Together, these assessments help the public and private sectors understand the terrorist financing, proliferation financing, and money laundering methods used in the United States, the threat actors behind these methods and vulnerabilities exploited, and the risks that these activities pose to the U.S. financial system and national security. In doing so, these assessments enable U.S. Government agencies to better understand and therefore more effectively combat illicit actors seeking to exploit the U.S. financial system. They also assist the private sector in detecting the exploitative tactics used by these threat actors, allowing financial institutions and other private sector stakeholders to better mitigate their illicit finance risk.

The National Illicit Finance Strategy describes the strengths of U.S. counter-illicit finance efforts, including a robust legal and regulatory framework; authorities, capabilities, and initiatives by U.S. departments and agencies, and highlights efforts underway to improve the effectiveness of national safeguards in place in light of changes in technology and emerging threats.  Such efforts include a working group formed by Treasury’s Office of Terrorism and Financial Intelligence and the Federal depository institutions regulators on Bank Secrecy Act/Anti-Money Laundering (BSA/AML) that is exploring ways to modernize the regulatory regime in ways that support innovative efforts by financial institutions to devote their resources towards addressing the areas of highest risk for illicit finance activities.

The National Illicit Finance Strategy and risk assessments were prepared by the Office of Terrorist Financing and Financial Crimes, an office within Treasury’s Office of Terrorism and Financial Intelligence, in consultation with the many agencies, bureaus, and departments of the federal government that also have roles in combating illicit finance.

The 2018 National Illicit Finance Strategy.
The 2018 National Money Laundering Risk Assessment.
The 2018 National Terrorist Financing Risk Assessment.
The 2018 National Proliferation Financing Risk Assessment.

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