Ownership Transparency

The U.S. is the easiest place in the world for a criminal, terrorist, tax cheat, or kleptocrat to open an anonymous shell company to launder their money with impunity. Anonymous corporations are great ways to hide money and other assets — they can hold a bank account or buy a yacht. Criminals often layer anonymous corporations, with one owning another and so on, making it even harder for law enforcement to “trace the money” and figure out who is directing the company’s activity. It’s time to ending the use of anonymous shell companies as vehicles for illicit activity by requiring that the true owners of U.S. companies be disclosed at the time of formation and updated upon any change.

Testimony of Dalia F. Martinez, Executive Vice President of Operations International Bank of Commerce before the Subcommittee on Financial Institutions and Consumer Credit, April 27, 2018

Chairmen Leutkemeyer and Pearce, Ranking Members Clay and Perimutter and members of the subcommittee, I am honored to have this opportunity to present testimony today regarding FinCEN’s Customer Due Diligence Rule. I am Dalia F. Martinez, Executive Vice President and Corporate Bank Secrecy Act Officer for International Bank of Commerce. IBC Bank–Laredo is a member of International Bancshares Corporation (NASDAQ: IBOC), a $12.2 billion multi-bank financial holding company headquartered in Laredo, Texas, with 192 branches and more than 294 ATMs serving 90 communities in Texas and Oklahoma. I am speaking to you today representing the Mid-size Bank Coalition of America, the voice of 88 community banks with headquarters in 34 States. MBCA banks are primarily between $10 billion and $50 billion in assets with more than 10,000 branches in all 50 states, with deposits of $1.2 trillion. MBCA banks represent, service, and support millions of customers.

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Testimony to House Financial Services Committee on Implementation of FinCEN’s CDD Rule

Gary Kalman, the executive director of the Financial Accountability and Corporate Transparency (FACT) Coalition, testified in front of the U.S. House of Representatives Committee on Financial Services Subcommittee on Financial Institutions and Consumer Credit on Friday, April 27, 2018 at a hearing regarding the implementation of the Financial Crimes Enforcement Network’s (FinCEN) rule on Customer Due Diligence Requirements for Financial Institutions.

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Countering a Kleptocratic Kremlin

With every passing week we have new evidence of the threat that Vladimir Putin’s kleptocracy poses to our democracy, our national security, and the entire liberal world order. Putin’s regime—something akin to an organized crime ring masquerading as a state—has looted the wealth of Russia, subjugated its people, attacked neighboring former republics of the USSR, annexed Crimea, and hacked the electoral process in the United States and other Western democracies.

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Steps Congress can take to defend America against foreign influence operations

Last week, Lt. Gen. H.R. McMaster conceded that, “We have failed to impose sufficient costs… [on Russia for the Kremlin’s use of]…new and old forms of aggression to undermine our open societies.” Special Counsel Robert Mueller’s recent indictment of Russia’s Internet Research Agency and related individuals, made clear the extent of the operation attacking our country’s elections and institutions. And yet, more than a year after the 2016 presidential election, and with mid-term elections looming on the horizon, little has been done to increase America’s defenses against the threat of foreign interference in our democracy or impose costs on those who do.

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Just the FACTs: April 19, 2018

In January, we were optimistic that this would be the year anonymous companies would end.  Since then, the momentum for disclosure has only grown. Legal scholars and international affairs experts have recently called for action, a recent poll showed overwhelming support from small businesses, and a report from Fair Share reminded us that anonymous companies are continuing to fuel the opioid epidemic.  Between these and a recent investigation by Reuters that found Russians are using a web of anonymous companies to skirt U.S. sanctions and boost the government of Syria’s Bashar al-Assad, Iran’s Revolutionary Guard, and the Hezbollah militia, the arguments for secrecy are becoming more and more invalid.

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Tracking Illicit Russian Financial Flows

Trillions of dollars in capital flows into the United States annually, and trillions of dollars in payments are cleared through New York daily. No one knows exactly whom the funds belong to, where they are held, or how they are deployed. No one knows because the U.S. government does not track the money — but it could if it wanted to. What is known is that Russia, other countries of the Commonwealth of Independent States, and China are the primary drivers of non-transparent capital flows worldwide.

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