“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
Treasury Delays Implementation of Landmark Rule to Fight Money Laundering in $130 Trillion Private Investment Sector
On July 21, the Financial Crimes Enforcement Network (FinCEN) announced that it plans to postpone and revise a long-overdue rule introducing anti-money laundering safeguards in the U.S. private investment sector. The rule – subject to potential revisions – is now set to take effect on January 1, 2028, nearly two years after the original effective date.
Last year’s rule marks the third time FinCEN has attempted to institute anti-money laundering requirements for the private investment sector. For over two decades, the industry has received a series of “temporary” exemptions from the kinds of anti-money laundering obligations mandated for nearly every other major class of financial institution, including banks, broker-dealers, and commodity brokers.
In a statement, FACT executive director Ian Gary warned that “Treasury is kicking the can on already long overdue anti-money laundering safeguards, [and sending] a signal to criminals and U.S. adversaries that they can continue to move illicit funds through the massive and opaque U.S. private investment sector with impunity.”
Criminals and U.S. adversaries often turn to the U.S. private investment industry to launder their proceeds, defraud American investors, and undermine national security. This decision is the latest in a series of recent actions taken by Treasury to roll back long-awaited updates to U.S. anti-money laundering standards, including the decision in March to effectively eliminate beneficial ownership reporting requirements under the landmark Corporate Transparency Act.
Bipartisan Bill to Curb Money Laundering and Terror Financing Threats in U.S. Art Market Introduced
On July 23, the Art Market Integrity Act, a commonsense proposal to apply anti-money laundering safeguards to high-risk art transactions, was introduced by a bipartisan group of six Senators, led by Senators John Fetterman of Pennsylvania and Chuck Grassley of Iowa.
The art market has long been a blind spot in the U.S. anti-money laundering framework, used by criminals to move and hide illicit funds, finance armed conflict and terrorism, and evade U.S. sanctions. This bipartisan bill fights back by adding art dealers and auction houses to the Bank Secrecy Act’s (BSA) list of regulated financial institutions.
The Antiquities Coalition, a FACT Coalition member, played an indispensable role in championing this important bill. From their press release: “The Antiquities Coalition has long advocated for targeted reforms to prevent the exploitation of art and antiquities by criminal networks. In 2021, Congress took a critical first step by extending the BSA to the antiquities trade, but left high-value art transactions unaddressed. The Art Market Integrity Act would level this playing field.”
House Proposes Further Devastating Cuts to IRS Enforcement
On July 20, the House Appropriations Financial Services and General Government Subcommittee advanced a proposed spending package that would cut the overall IRS budget for FY26 by nearly a quarter compared to current enacted levels, including a staggering 45 percent cut to enforcement funding, even deeper than the 34% cut proposed by the Trump administration’s budget request. The House proposal, if passed into law, would devastate the IRS’s ability to investigate tax evasion, particularly complex tax cases against large corporations and wealthy individuals.
Since 2010, the IRS has lost roughly half of its personnel specializing in these complex tax investigations and enforcement cases. While Congress made significant investments in IRS enforcement in 2022, almost all of that progress has now been reversed, with recent staff cuts significantly hindering the ability of the IRS to enforce tax law, in particular investigations of major cross-border tax cases. Nonenforcement of a single transfer pricing rule against just ten major multinational corporations alone has reportedly cost the U.S. as much as $600 billion in recent decades.
FACT’s tax policy platform includes increased IRS funding for audit and enforcement actions as one of five policy reform pillars, and FACT policy director Zorka Milin testified to the importance of adequately funding the Service before the Senate Budget Committee in April 2024.
The same July 20 proposal from the House would also withhold funds from the Financial Accounting Standards Board (FASB) unless it withdraws an improved tax reporting standard adopted in late 2023 that provides material information to investors. FACT continues to oppose the House proposal and supports the FASB’s independence from political interference.
Latest from FACT
Wall Street Journal: Be Transparent About Shells
FACT deputy director Erica Hanichak’s new letter to the editor in the Wall Street Journal calls attention to the obstacles faced by U.S. customs officials as a result of their lack of access to information about the true owners of anonymous shell companies.
“Our nation’s adversaries and competitors shouldn’t be able to weaponize U.S. financial secrecy to dodge tariffs and undercut law-abiding U.S. businesses. The competitiveness of U.S. manufacturers depends on it.”
Policy Brief: Dissecting Congress’s $170b Tax Cut for U.S. Multinational Corporations
Read FACT’s latest policy brief detailing the most important international corporate tax changes introduced by the 2025 tax reform law, including major revisions to the taxation of U.S. corporations’ foreign and export income.
“While the 2025 tax law’s international tax provisions have been labelled “America-first”, in reality, most of the changes will lower the effective tax rates multinationals pay on foreign income, and therefore further incentivize the continued movement of investment and income abroad.”
FACT in the News
Wall Street Journal: U.S. Exporters Get Welcome Surprise in Trump Tax Law
Zorka Milin was quoted by the Wall Street Journal in their coverage of Congress’ recent expansion of the Foreign-Derived Intangible Income tax break, which provides a steep tax discount largely benefiting a small handful of huge, hyper-profitable U.S. corporations.
“[These companies are] getting, I would say, an even more generous tax break for a policy that is untested. It could maybe add a tax reward for something that companies might be doing anyway,” said Milin.
International Tax Review: US Corporate Investors Back PCbCR Despite Government Snub – FACT Director
Ian Gary was interviewed by International Tax Review on the long-running support from U.S. corporate investors for enhanced corporate tax transparency. Last year, FACT filed a petition on behalf of investors with more than $2.3 trillion in assets under management, calling on the SEC to require public country-by-country reporting for U.S.-listed companies.
“FACT has been getting really good feedback from institutional shareholders – they’re concerned about the tax risk that companies may face if they’re employing aggressive tax avoidance strategies,” said Gary.
From Our Members and Allies
Public Citizen: New Bill Would End $190 Billion in Polluter Subsidies
The End Polluter Welfare Act – which would repeal roughly $190 billion in subsidies for the U.S. oil and gas industry, including numerous tax breaks for oil and gas production abroad – was reintroduced in both chambers of Congress on July 25. The legislation has been endorsed by the FACT Secretariat, FACT Steering Committee members Public Citizen and Friends of the Earth U.S., and over 175 other groups.
In a statement, Meghan Pazik, senior policy advocate with Public Citizen’s Climate Program, said that “the End Polluter Welfare Act would rein in the corporate power of fossil fuel interests. Ending these subsidies isn’t just good policy and responsible government tax reform—it’s climate justice.”
Environmental Investigation Agency (EIA): Toxic Tons – The Largest Flow of Illegal Mercury to the Amazon Exposed
Read the new report from FACT Environmental Crimes Working Group member EIA, which details the large-scale trafficking of mercury – a crucial and environmentally-destructive component in illegal gold extraction – from Mexico to gold mines in Bolivia, Colombia, and Peru. Between April 2019 and June 2025, the trafficked mercury generated a minimum of US$8 billion worth of illegal gold, EIA estimates, in a trafficking scheme that involved the use of opaque company structures and frontmen.
From the report: “Mercury should be treated as what it is: a highly toxic catalyst of convergent crimes including human rights violations, arms trafficking, drug trafficking, and illegal natural resource extraction. Allowing the continued production of mercury in Mexico until 2032 – with its attendant deadly effects on natural ecosystems and people – will in practice create deadly lasting effects for generations in Mexico and across Latin America.”
Transparency International U.S: Dismantling Transnational Anti-Corruption Framework Is Dangerous and Costly
A new op-ed from Gary Kalman, executive director of FACT member Transparency International U.S., warns that recent actions by the Treasury to dismantle anti-corruption initiatives will be costly for the American and global economy.
From the op-ed: “In the end, strong transparency and accountability measures save money and lives. The dismissal and dismantling of the existing U.S. financial transparency framework takes all of us—the country and global economy—down a dangerous and costly path.”
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