U.S. Department of Treasury Summary: 2024 National Strategy for Combatting Terrorist and Other Illicit Financing

U.S. Department of Treasury Summary: 2024 National Strategy for Combatting Terrorist and Other Illicit Financing

NASCUS Legislative and Regulatory Affairs Department
May 23, 2024

With little fanfare, on May 16, 2024 the U.S. Department of Treasury issued its 2024 National Strategy for Combatting Terrorist and Other Illicit Financing. The document is 55 pages and according to Treasury’s press release, “addresses the key risks from the 2024 National Money Laundering, Terrorist Financing, and Proliferation Financing Risk Assessments.”

The document is extensive and discusses a lengthy list of topics. At a high level, it identifies four “priorities” and 15 “supporting actions” to support the four priorities. Each of the priorities and supporting actions is to support the goals of the U.S. Anti-Money Laundering/Countering Financial Terrorism regime.

The four priority recommendations according to the press release and report are:

  1. 1Close legal and regulatory gaps in the U.S. AML/CFT framework that illicit actors exploit to anonymously access the U.S. financial system by operationalizing the beneficial ownership information registry for law enforcement, national security, and intelligence use; finalizing rules related to the residential real estate and investment adviser sectors; and assessing other sectors that may be vulnerable to illicit finance;
  2. Promote a more effective and risk-focused U.S. AML/CFT regulatory and supervisory framework for financial institutions to make them more efficient and effective in preventing illicit finance by providing clear compliance guidance, sharing information appropriately, and ensuring adequate resourcing for supervisory and enforcement functions;
  3. Enhance the operational effectiveness of law enforcement, other U.S. government agencies, and international partnerships in combating illicit finance so threat actors cannot find safe havens for their operations; and
  4. Realize the benefits of responsible technological innovation in the United States by developing new payments technology, supporting the use of new mechanisms for private sector compliance, and utilizing automation and innovation to find novel ways to combat illicit finance.

The report also includes a graphic that details the primary goals, priorities, and supporting actions.

While these are laudable goals the report also leads one to question how Treasury will accomplish these goals as the document acknowledges the lack of government resources, particularly when it comes to monitoring non-bank financial institutions, which are becoming a much greater focal point.