“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
Big U.S. Corporations Are Still Playing Tax Haven Games – FACT Analysis of Newly-Required Tax Disclosures
FACT’s analysis of new corporate tax disclosures shows that U.S. anti-abuse rules remain far too weak to stop large corporations from shifting profits to tax havens. Forty large, profitable U.S. multinational corporations reduced their tax bills by more than $11 billion through the use of tax havens in 2025, while U.S. anti-abuse rules meant to deter profit shifting clawed back less than $3 billion of those savings. These tax haven figures are conservative estimates and are likely to grow substantially as more major corporations publish their annual financial statements in the coming months, including Apple, Microsoft, Cisco, McKesson, Nike, and others.
The new tax disclosures are the result of improved accounting standards intended to better inform investors about the tax risks of companies in their portfolios. FACT’s analysis found that just 10 U.S. pharmaceutical and biotech companies account for over half of all reported tax haven savings.
Offshore tax avoidance by American pharmaceutical companies has been investigated by the Senate Finance Committee. Ireland plays a particularly important role: according to economist Brad Setser, Irish earnings of foreign multinationals (almost all American-headquartered) are on track to exceed $300 billion in 2025, a figure that has grown steadily despite multiple rounds of U.S. and global tax reforms.
These trends are likely to continue following the 2025 U.S. tax reform and the recent OECD agreement, which both failed to meaningfully improve how U.S. multinational companies are taxed. The U.S. still taxes foreign profits at a steeply discounted rate when compared to domestic income, and does so in a manner that is generally more lenient than comparable international standards negotiated at the OECD.
Treasury’s New Money Laundering Risk Assessment Reaffirms Many Known Threats, But Downplays Domestic Shell Companies
The new National Money Laundering Risk Assessment – a semi-annual document published by the Treasury that establishes the administration’s political and policy priorities with regard to tackling illicit finance vulnerabilities – both reaffirms the importance of central pillars of the U.S. anti-money laundering framework and rejects certain critical new tools to fight dirty money.
In particular, the Risk Assessment reaffirms the central role that residential real estate transactions play in many money laundering schemes, and defends Treasury’s recently-implemented reporting requirements for certain all-cash real estate transactions as an essential tool to make law enforcement investigations “less costly, less lengthy, and more effective.” Similarly, the Assessment acknowledges substantial vulnerabilities in the private investment sector, though it does not comment on the administration’s decision to delay and potentially “re-scope” the 2024 final rule introducing new anti-money laundering requirements for the sector.
While the top illicit finance vulnerabilities identified in the assessment largely remain consistent with previous years – including fraud, drug trafficking, human trafficking, and corruption – less emphasis has been placed on the role that shell companies play in facilitating money laundering associated with these crimes. In line with the disastrous decision by Treasury to limit reporting requirements under the Corporate Transparency Act (CTA) to only foreign entities and individuals, the 2026 Risk Assessment asserts that U.S. law enforcement already has a “broad range of tools they can employ to identify the beneficial owners of U.S. legal entities,” despite substantial evidence that opaque domestic shell companies remain one of the most significant anti-money laundering vulnerabilities in the U.S.
For more information on Treasury’s recent rule restricting reporting requirements under the CTA to foreign companies, as well as additional evidence for the substantial illicit finance vulnerability posed by domestic shell companies, see FACT’s official comments.
FACT in the News
Business Insider: The U.S. is Colombia’s Top Gold Customer — And Cartels Know It
FACT program director for environmental crime Julia Yansura was featured extensively in a new documentary by Business Insider covering the U.S.’ status as the largest importer of Colombian gold. Illicit gold has emerged in recent years as a top source of income for transnational drug cartels, armed groups, and other criminal actors in Colombia and throughout the Western Hemisphere.
“If we want to help shut down this problem, we need to do more from the U.S. side,” Yansura said, adding that “the financial sector is massively exposed to [illicit gold] risks, yet they’ve received very little guidance from U.S. regulators about how they should be managing them.”
Yansura also called for solutions that go beyond traditional enforcement crackdowns. “There’s a myth that we can solve this problem by sending out police and military to blow up the heavy machinery at illegal mining sites. But within as little as an hour, the criminal groups are back,” Yansura said. Instead, authorities must crack down on the dirty money that fuels this criminal economy.
Watch Business Insider’s full documentary, including Yansura’s remarks, here:
The Big Picture: Ian Gary on the Current State of Financial Secrecy in the U.S.
FACT executive director Ian Gary appeared on It’s the Democracy, Stupid with Edwin Eisendrath (formerly The Big Picture) to discuss Treasury’s gutting of the Corporate Transparency Act, the connection between environmental crimes and illicit finance, and more.
Listen to the whole interview here:
Washington Post: Fossil Fuel Giant Wins $370 Million Tax Break for Burning Gas as an ‘Alternative Fuel’
FACT policy director Zorka Milin was quoted by the Washington Post in their coverage of a “questionable” $370 million tax break given to Cheniere, one of the world’s largest exporters of natural gas.
The IRS granted Cheniere a tax credit for so-called “bunker” fuel used to power its enormous shipping fleet from 2018 to 2024. The credit statutorily only applies to natural gas-fueled “motorboats,” generally defined as shorter than 65 feet. “I am not sure how they could reach this conclusion,” Milin said of the IRS decision.
Law360: Feds’ White Collar Crime Enforcement ‘Retreat’ Raises Alarms
FACT’s deputy director Erica Hanichak was quoted by Law360 in their coverage of the decline in white-collar crime enforcement, linking it to the ongoing mutual evaluation of the United States by the Financial Action Task Force (FATF).
From the article: The enforcement focus and resource shift also come as the U.S. faces the “biggest evaluation of the strength of its anti-money laundering standards” in a decade, noted Erica Hanichak, deputy director at FACT….“We’ll see what FATF decides. But I think for an appropriate assessment, FATF should express concern about the state of enforcement in the U.S.”
From Our Members and Allies
Transparency International U.S: America’s ethics laws were written for a different era
A new op-ed from FACT-member Transparency International U.S. examines federal anti-bribery laws and identifies several blind spots that still allow billion-dollar deals to slip through.
From the op-ed: “Around the world, the pattern is familiar: A foreign government or sovereign-linked actor identifies an incoming leader or political family. Money moves early, often before formal power is assumed. The investment is framed as commercial, not political. Later, favorable policy decisions follow…. The U.S. still has a choice. It can treat these episodes as isolated controversies, or it can recognize a pattern that anticorruption experts know well and close the gaps before they become permanent features of American government.”
Earth League International: MONEY TALKS: What Criminals Told Us About Corruption
A new report from Environmental Crime Working Group member Earth League International (ELI) exposes how corruption serves as a central engine for environmental crime. ELI’s report is unique in that it utilizes direct, firsthand testimony of the criminals themselves. The report offers a rare view of how corruption operates in practice, analyzing over a decade of undercover field operations across Latin America, Africa, Southeast Asia, and Europe.
From the report: “As corruption shields [transnational criminal organizations (TCOs)] from accountability, they grow wealthier, which in turn makes them bigger, stronger, and more resilient. Protected proceeds allow TCOs to diversify their activities–both licit and illicit–increasing their adaptability and ability to survive disruption efforts that focus on only one revenue stream.”
Sembrando Sentido: Good tax policies require transparency
A new op-ed from FACT-member Sembrando Sentido argues that Puerto Rico’s “tax haven model” lacks the transparency and accountability necessary to ensure that both new and historic policies are in the public interest.
From the op-ed: “As members of the PR No Se Vende Coalition, we insist: good tax policies, or public policies of any kind, cannot be designed without accurate data, complete methodologies, and analysis focused on the public good, not on convenient blindness or private interests.”
FACT Members Endorse Fossil Fuels Windfall Profits Tax as Gas Prices Soar
FACT member organizations including Friends of the Earth and Public Citizen endorsed a letter urging top federal lawmakers to adopt a windfall profits tax for the American oil and gas industry as the Iran conflict continues to drive up domestic gas prices. A bill that would impose such a tax was reintroduced in both chambers of Congress by Senator Sheldon Whitehouse (D-RI) and Representative Ro Khanna (D-CA-17) on March 17.
From the letter: “This approach has overwhelming public support. During the last global energy price spike in 2022, roughly 80 percent of Americans supported a windfall profits tax on oil companies, reflecting broad frustration with corporations recording record profits while families struggle with rising fuel costs. Recent reports have found that redistributing excess fossil fuel profits resulting from Russia’s invasion of Ukraine could have returned roughly $1,715 to every American household.”
Recent and Upcoming Events
March 17: EU Tax Symposium – “The Future of Taxation: Inequality and Growth in the Global Economy”
On March 17, as part of the EU tax symposium, Zorka Milin spoke on a panel titled “From Pillar Two to a side-by-side approach: what future lies ahead after the G7/G20 agreement?” Alongside speakers from the UK government and the private sector, Milin discussed the OECD’s recent agreement that exempts U.S. corporations from certain provisions of the “Pillar Two” global corporate minimum tax.
A livestream of Milin’s panel can be found here, and was covered by Law360.
March 16: Law Enforcement Voices Brief Policymakers on Need to Strengthen Anti-Money Laundering Reforms
FACT joined representatives from state, local, and federal law enforcement groups at a briefing for House policymakers on the need to strengthen and preserve core pillars of the U.S. anti-money laundering framework. As the primary users of tools designed to help investigators follow the money, law enforcement groups have been among the most vocal proponents of enhanced beneficial ownership transparency under the Corporate Transparency Act, new rules targeting money laundering through residential real estate transactions, and other recent AML policy developments.
About the FACT Coalition