“Just the FACTs” is a round-up of news stories and information regarding efforts to combat corrupt financial practices, including offshore tax haven abuses, corporate secrecy, and money laundering through the financial system.
Send feedback or items for future newsletters to Thomas Georges at tgeorges@thefactcoalition.org
State of Play
Legal Victory for Landmark Anti-Money Laundering Regulation for Real Estate Transactions
On February 19, the U.S. District Court in Jacksonville ruled in favor of the government in a case challenging Treasury’s landmark new anti-money laundering requirements for the residential real estate industry. The court held that Treasury’s rule is authorized by the Bank Secrecy Act and does not violate either the First or Fourth Amendments. The plaintiffs may still appeal this decision, but any such appeal will not affect the March 1, 2026 effective date of the new reporting requirements.
The U.S. real estate sector has long been a significant vector for financial crime. Money laundering through real estate both “distorts housing prices and threatens U.S. economic and national security,” according to the U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN). Treasury’s 2024 National Money Laundering Risk Assessment names U.S. real estate as a common money laundering avenue due to its value and stability, as well as the ease with which criminals can conduct anonymous transactions through LLCs and trusts. Until now, the industry’s relative opacity has made it difficult for law enforcement to follow the money and pursue investigations involving real estate money laundering. The implementation of the residential real estate rule will mark a substantial leap forward for the U.S. anti-money laundering framework, helping to protect communities against the harms associated with illicit finance.
FACT Hosts Author Oliver Bullough for Virtual Book Talk
Today, FACT hosted a conversation with Oliver Bullough, author of the new book Everybody Loves Our Dollars – How Money Laundering Won. Bullough joined FACT executive director Ian Gary to explore his book’s findings, and how politicians and regulators can more effectively tackle the scourge of dirty money.
Bullough discussed challenges impeding the effectiveness of the global anti-money laundering (AML) framework. In particular, he examined the Financial Action Task Force (FATF), the intergovernmental body responsible for setting global standards for combating money laundering, whose “one-size fits all” approach to AML Bullough argues leaves many of the most prominent financial hubs – including the U.S., UK, and other highly developed economies – off the hook while punishing smaller, lower risk jurisdictions.
FATF is set to evaluate the U.S.’ anti-money laundering framework this year. As FACT has pointed out, the Trump administration has significantly undermined key aspects of the U.S. anti-money laundering framework, most notably the Corporate Transparency Act, which requires companies to disclose their true, so-called “beneficial” owners. Bullough predicts that this evaluation will be “a real challenge,” saying that “[FATF] is one of those organizations where if you’re not at the table, you’re on the menu, and the countries that are at the table are the big Western economies…If you do criticize the U.S., it’s hard to believe that the current Administration is going to take that kindly, but if you don’t criticize the U.S., it’s hard to believe the rest of the world will take that kindly.”
Treasury Weakens U.S. Corporate Minimum Tax, Costing Billions in Lost Revenues
On February 18, Treasury issued new guidance effectively exempting tens of billions of dollars of corporate income from the 15 percent Corporate Alternative Minimum Tax (CAMT), a critical backstop that limits how much America’s largest companies can benefit from certain deductions and tax credits. After roughly $1 trillion in corporate tax breaks were renewed and expanded in the 2025 budget reconciliation bill, last week’s unlegislated tax cut by Treasury could further increase the cost of one of the bill’s most expensive corporate provisions.
FACT policy director Zorka Milin cautioned against this exact move by Treasury in a Bloomberg op-ed last December, in which she wrote that “The Treasury Department is required to consider the Congressional intent behind enacting CAMT. It shouldn’t risk ballooning the cost of a tax reform largely paid for with deep cuts to vital health and nutrition programs for ordinary Americans, with the benefits flowing to the largest, most profitable corporations.”
FACT allies and coalition members have come to similar conclusions. In response to the new guidance, Deputy Director of the NYU Tax Law Center Michael Kaercher noted that “Only Congress can repeal CAMT and yet it would be surprising if this guidance leaves any meaningful CAMT revenue to collect.” Amy Hanauer, Executive Director of the Institute for Taxation and Economic Policy (ITEP), likewise argued that the administration “appears intent on achieving through illegal regulations what it was unable to do through the legislative process last summer: a gradual repeal of an important bulwark against corporate tax avoidance.”
FACT in the News
The Hill: What US taxpayers should be asking about Venezuela and foreign oil
Read FACT executive director Ian Gary’s latest op-ed in the Hill on how the U.S. tax code subsidizes overseas fossil fuel production. Citing FACT’s latest report, America-Last and Planet-Last: How U.S. Tax Policy Subsidizes Oil and Gas Extraction Abroad, Gary highlighted the fact that U.S. oil and gas multinationals collectively pay billions more in taxes to foreign governments than to the U.S. Treasury, despite collectively producing more oil and gas domestically than abroad.
ICIJ: As Crypto Industry Expands, U.S. Slashes Office Examining Dirty Money Safeguards of Cryptocurrency Exchanges
FACT deputy director Erica Hanichak was quoted by ICIJ’s Spencer Woodman in his coverage of recent cuts to the IRS’ anti-money laundering unit, and the dire implications for enforcement of AML laws against cryptocurrency exchanges and other money service businesses.
“The reduction in supervisory staff at the IRS matches a trend we’ve seen across [anti-money laundering] enforcement agencies,” said Hanichak. “This sends the signal that the U.S. is open to dirty money. It undermines our national security and market integrity.”
Coda: The War Against Corruption: Why Corruption is Winning
FACT’s recent blog on the improved accounting rules at the Financial Accounting Standards Board (FASB) was cited by Oliver Bullough for Coda.
“Thanks to new accounting rules, it is possible to see how and where U.S. corporations pay tax. Some of the results are pretty remarkable: Boeing pays more tax in Germany than in the United States; Tesla pays only $28 million to the U.S. Treasury, fully 27 (!) times less tax than it pays in China,” wrote Bullough.
Bloomberg Tax: Companies’ Big Overseas Tax Bills Spur Profit-Shifting Concerns
Zorka Milin was quoted by Bloomberg Tax in their coverage of new tax disclosures that reveal how the U.S. tax code continues to incentivize American companies to park their profits in tax havens.
“These new disclosures are a major improvement on what we’ve had before…the hope is that with more public scrutiny, big multinationals are less likely to play offshore tax games that put investors at risk.”
From Our Members and Allies
UNICRI: Empowering Investigative Journalism on Environmental Crime: Insights from a Global Training
A new paper from the United Nations Interregional Crime and Justice Research Institute, the Nature Crime Alliance, and the FACT Coalition outlines the challenges faced by journalists reporting on environmental crime based on a 3-day training held in late 2025. Challenges identified by journalists include lack of funding for investigations and limited access to datasets and satellite imagery. Personal safety risks and gaps in technical and investigative skills were also cited as significant barriers to effective reporting.
The survey highlights a global need for more financial and technical support for environmental crime journalism, with respondents citing a need for fellowships and grants, improved access to data, and mentorship opportunities. FACT and its partners hope that this briefing paper inspires future actions by international organizations, media companies, funders, civil society and other stakeholders to address the needs identified and to empower the vitally important work of environmental journalism.
Center for American Progress: Five Hidden Ways The Government Tilts The Playing Field In Favor Of Fossil Fuels
A new report from the Center for American Progress (CAP), which was peer-reviewed by FACT staff, reveals that the U.S. has historically subsidized fossil fuels at far higher levels than renewable energy sources. The report analyzes data from the Joint Committee on Taxation (JCT) on tax expenditures supporting oil, gas, coal, wind, and solar at both the corporate and consumer levels, and finds that the oil, gas, and coal industries have received nearly three times more subsidies by dollar value than the renewable energy industry.The report highlights tax subsidies for fossil fuels, including subsidies for American companies drilling abroad – the subject of FACT’s latest report, America-Last and Planet Last.
From the CAP report: “The so-called ‘dual capacity taxpayer’ provision allows U.S. fossil fuel companies to claim outsize foreign tax credits at home. While most companies are allowed to claim credits for income taxes paid to foreign governments, the oil and gas sector is allowed to claim credits for nontax payments, including royalties for drilling. Across all sectors, this tax break costs taxpayers a massive $3.5 billion to $7.2 billion annually.
Recent and Upcoming Events
Watch: UN Expert Group on Crimes Affecting the Environment: Minerals Crime – Challenges and Responses
On February 25, FACT program director for environmental crimes Julia Yansura spoke at a United Nations event hosted by the Government of Peru on the challenges posed by mineral crimes.
EU Tax Symposium “The future of taxation: inequality and growth in the global economy” in Brussels and online
As part of the EU tax symposium on March 16-17, FACT policy director Zorka Milin will speak on a panel titled “From Pillar Two to a side-by-side approach: what future lies ahead after the G7/G20 agreement?” You can register to attend in person at the European Parliament in Brussels, or tune in remotely.
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