U.S. Treasury Terrorism and Financial Intelligence ("TFI") Undersecretary Sigal Mandelker detailed the Division's efforts to administer U.S. economic sanctions authorities, and to combat money laundering and terrorist financing ("AML/CFT").

In a statement before the U.S. House Appropriations Subcommittee on Financial Services and General Government, Ms. Mandelker highlighted the following activities undertaken by the TFI (which comprises the Office of Foreign Assets Control ("OFAC"), the Financial Crimes Enforcement Network ("FinCEN"), the Office of Intelligence and Analysis, and the Office of Terrorist Financing and Financial Crimes):

  • maximizing economic pressure on Iran to address its weapons proliferation, terrorism and "regionally destabilizing activities";
  • conducting a robust campaign to counter Russian "malign activity," including Russia's attempt to undermine Western democracies;
  • targeting illicit financial hubs where Russian, North Korean and other actors seek to "obscure the origins and sources of funds"; and
  • imposing pressure on North Korea (e.g., the Trump administration has issued advisories to the international community with regard to North Korea's "deceptive shipping practices, its abuse of the international financial system, and its risks to the integrity of global supply chains").

Ms. Mandelker emphasized the importance of ensuring that AML/CFT safeguards are effective, and stated that TFI must make certain that (i) financial institutions are devoting their resources toward activities that concern "priority illicit finance risks" and (ii) the U.S. Treasury Department is partnering with the private sector, law enforcement and regulatory colleagues.

Additionally, Ms. Mandelker noted that the lack of consistent global AML/CFT regulation of digital assets compounds the money laundering and illicit finance risks. Ms. Mandelker also underscored that OFAC compliance obligations for U.S. persons are the same regardless of whether a transaction is "denominated in non-national virtual currency, national digital currency, or traditional fiat currency."

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