Briefing Memos

In Brief: About FACT’s Work on Environmental Crime and Illicit Finance

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About FACT

The Financial Accountability and Corporate Transparency (FACT) Coalition is a non-partisan alliance of more than 100 state, national, and international organizations working toward a fair tax system that addresses the challenges of a global economy and promoting policies to combat the harmful impacts of corrupt financial practices. Founded in 2011 in Washington, DC, the FACT Coalition draws on a diverse and active membership that includes environmental, labor, faith, and anti corruption groups.  

Today, FACT is a leading U.S. voice working to combat money laundering, tax evasion, and the harms caused by financial secrecy. Most recently, FACT’s work has included policy advocacy demonstrating the harms caused by the use of anonymous shell companies and promoting the creation of a registry of the real or “beneficial” owners of these companies in the United States. Following the passage of the bipartisan Corporate Transparency Act (CTA) in 2021, arguably the most significant anti money laundering reform in two decades, FACT has closely engaged with U.S. policymakers to support robust, meaningful implementation of the directory. 

Additionally, FACT has advocated for effective anti money laundering controls over the U.S. real estate and private investment sectors, which have long been vulnerable to abuse by financial criminals

Key to FACT’s work is the belief that the U.S. can and must be a good global citizen. Our work is motivated by the belief that addressing illicit finance will not only make the U.S. safer and more equitable, but that it will also have benefits for our friends, neighbors, and allies around the world. 

FACT’s Environmental Work

In 2022, FACT convened more than 60 advocates and experts from government, international organizations, and civil society to share lessons learned on the intersection of illicit finance and environmental crimes. Building on this foundation, in 2023 FACT formally launched a new line of work looking at the intersection between environmental crime and illicit finance. Through advocacy, research and capacity building, FACT seeks to close anti money laundering loopholes that allow the proceeds of environmental crime to be laundered into the U.S. financial system. 

In October 2023, FACT launched an agenda-setting report titled Dirty Money and the Destruction of the Amazon: Uncovering the US Role in Illicit Financial Flows from Environmental Crimes. The report, which draws on expert interviews as well as analysis of environmental crime cases, finds that financial secrecy in the United States is providing safe haven to illicit proceeds from illegal logging and illegal mining in the Amazon region. The report concludes with a series of 14 policy recommendations to close anti money laundering loopholes. The FACT Coalition hopes that the report, which was covered widely in US, UK, Peruvian, and Colombian media, will spur policy debate and, ultimately, policy action. 

Going forward, FACT will focus on the following activities to address environmental crime: 

  • Advocating for robust implementation of U.S. beneficial ownership laws in recognition of the outsized role that U.S. shell and front companies play in environmental crimes; 
  • Ensuring that international law enforcement can access U.S. beneficial ownership data to conduct environmental crime investigations, as legally permitted by the Access Rule of the Corporate Transparency Act;  
  • Encouraging and empowering investigators working on environmental crimes to “follow the money”; 
  • Promoting a more active U.S. role in addressing environmental crimes in the Andes-Amazon region through increased enforcement, foreign assistance, and diplomatic leadership; 
  • Enhancing U.S. inter-agency coordination to address illicit finance and environment crimes; 
  • Advocating for legislative tools to address the challenges posed by environmental crime, including the FOREST Act, which would ensure that foreign environmental crimes are predicate offenses for money laundering in the U.S.;  
  • Conducting research on money laundering linked to environmental crime;
  • Participating in trainings, conferences, and events that draw attention to these issues and put forth serious, actionable policy solutions;
  • Engaging closely with US and international civil society groups, especially in Peru and Colombia, to exchange information and best practices as well as to build coalitions for change. Geographically, FACT’s environmental work is focused on US policy as it relates to the Andes-Amazon region. However, we are also closely following developments throughout the Western Hemisphere. 
Engaging with FACT

FACT welcomes opportunities to engage with governments, civil society, international organizations, media and the private sector. Some of the ways to engage include,

  • Sign up for our updates: FACT regularly publishes a newsletter called Just the FACTs that provides technical updates on beneficial ownership, environmental issues, tax transparency, and more. You can sign up here
  • Follow us on social media: FACT is active on Twitter, where you can find updates on our advocacy activities, media hits, and more. 
  • Join our monthly Environmental Crime Working Group to coordinate and advocate for improved US policy related to environmental crime and illicit finance. For more information, please contact jyansura@thefactcoalition.org 
  • Invite us to speak: FACT Coalition staff include experts on financial transparency, beneficial ownership, anti money laundering, tax policy, environmental crime, and more. You can find our list of experts here. 

For more information, contact Julia Yansura, Program Director for Illicit Finance and Environment Crimes – jyansura@thefactcoalition.org