From Thomas Georges <[email protected]>
Subject FACT Calls for US Action on Illegal Gold, FinCEN Director Testifies in Wake of AML Rollbacks: Just the FACTs 9/18/25
Date September 18, 2025 5:22 PM
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September 18, 2025

"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 [email protected]

State of Play:
New FACT Research Calls for U.S. Action on Illegal Gold Mining

FACT's latest report, "Addressing Illegal Gold Mining in the Western Hemisphere: New Approaches for U.S. Policy", examines the destructive effects of illegal gold mining, with a focus on steps the U.S. can take to cut off the financial drivers of this crime. As the world's dominant financial power and one of the largest consumer markets for gold, the U.S.' policy decisions will be central to addressing the harms posed by illegal gold mining.

The report, authored by FACT program director for environmental crimes and illicit finance Julia Yansura and FACT Policy Fellow Isidoro Hazbun, analyzes the severity of the threat that the illegal gold trade poses across several Latin American countries and offers policy recommendations that the U.S. should take to address these threats. These recommendations include:

* Passing the United States Legal Gold and Mining Partnership Act, which would establish a multi-year strategy to reduce the environmental and social impacts of illegal gold mining in the Western Hemisphere.
* Making illegal gold mining an underlying, or "predicate" offense for money laundering, which would help U.S. prosecutors target illicit gold profits more effectively.
* Establishing a specific U.S. sanctions program targeting environmental crimes, including illegal gold mining.
* Fully implementing the Corporate Transparency Act (CTA) to end the abuse of anonymous companies by international and domestic criminals, including those involved in the illicit gold trade.
* Resuming recently-cancelled funding for international projects related to combating illegal gold mining, in line with U.S. interests.

Following the report's publication, Yansura appeared in coverage by various prominent news outlets, including News Nation Now, Telemundo, El Nuevo Herald, and Bloomberg.

Members of Congress Press Administration on Anti-Money Laundering Rollbacks

On September 9, the Director of the Financial Crimes Enforcement Network (FinCEN), Andrea Gacki, testified before the House Financial Services Committee, Subcommittee on National Security, Illicit Finance, and International Financial Institutions. During her appearance, Gacki reaffirmed the importance of the landmark residential real estate rule, which implements vital new safeguards against money laundering in the residential real estate market. This information has been "incredibly helpful to law enforcement across administrations... [and provides] benefits to the U.S. and Americans", Gacki said.

At the same hearing, Gacki also announced that FinCEN plans to delete ownership information submitted by U.S. companies under the Corporate Transparency Act (CTA). As FACT executive director Ian Gary told the International Consortium of Investigative Journalists in an interview, such destruction of company ownership data would be "doubling down on Treasury's unlawful gutting of this statute." This decision follows a March announcement that the Treasury would exempt domestic entities from reporting requirements under the CTA. Subcommittee Ranking Member Joyce Beatty took the opportunity to condemn the gutting of the CTA during last week's hearing, saying the decision "[makes] it easier for fentanyl traffickers and other criminals to launder money through the United States," and endanger Americans.

This hearing comes amidst increased Congressional scrutiny of the current Administration's retrenchment of the broader U.S. anti-money laundering framework. For example, an August report from the Minority Staff of the Senate Committee on Banking, Housing, and Urban Affairs found that recent anti-money laundering rollbacks "have caused concerning strain in staffing to support Russia sanctions and export controls...[undermining] our ability to maintain or expand" these controls. And just on Monday, Sen. Elizabeth Warren and Rep. Maxine Waters further questioned the decision to exempt domestic entities from beneficial ownership reporting requirements in a letter sent to Treasury Secretary Bessent. "Your decision to gut the law has caused growing alarm among law enforcement, inspectors general looking to fight fraud in U.S. government programs, and experts across the political spectrum that you are making it easier for criminals to take advantage of the financial system", the lawmakers wrote.

Read FACT's official statement for the record submitted for the hearing here.

Latest from FACT

FACT Submits Comments Calling on UN Tax Committee to Prioritize Country-by-Country Reporting

Read FACT's comments to the UN Tax Committee calling for increased global tax transparency in the form of public country-by-country reporting, which can improve tax administration and increase tax revenues for all countries, and particularly developing economies. The OECD's confidential country-by-country reporting regime has been transformational for those with access to it, but Global South nations have largely been frozen out of the exchange of collected information. FACT calls on the UN Tax Committee to prioritize increasing access to, and use of, public CbCR by Global South tax authorities.

FACT Submits Comments Calling for Limited Exemptions to Australia's New Tax Transparency Standard

Read FACT's official comments to the Australian government on the implementation of Australia's world-leading public country-by-country reporting regime.

From the comment: "FACT applauds the clear and consistent guidance provided to ATO officers to consider the law's primary policy intent, mandatory language, and supporting context derived from parliamentary debate and public consultations when considering exemption requests for public CBC reporting."

FACT in the News

The Miami Herald: 3 Family Members Accused of Smuggling Gold into Miami from Colombia

Julia Yansura was quoted by the Miami Herald in their coverage of money laundering charges against the defendants in an illegal gold smuggling case in Miami.

"Illegal gold mining is a regional crisis that undermines the rule of law, damages the environment, and fuels organized crime...With significant gaps in our anti-money laundering regulations and trade policies, the U.S. has become a hub for the proceeds of this crime, empowering criminal networks and authoritarian regimes in the process."

Thomson Reuters - Corporate Transparency Act Update

FACT deputy director Erica Hanichak was quoted by Reuters for their update on the state of the CTA in the wake of FinCEN Director Gacki's congressional testimony.

"FinCEN is violating the intent of Congress and tying the hands of law enforcement, making it harder to protect our communities... Despite testimony Tuesday acknowledging that domestic companies present risk of financial crime, FinCEN is doubling down on its unlawful gutting of this bipartisan law by announcing its intention to erase disclosures already made to the database."

Forbes - Getting To Know You Tuesday: Zorka Milin

FACT policy director Zorka Milin was profiled for Forbes' Getting To Know You series, where she answered questions about her background, life, and work at FACT.

If you've ever wanted to learn about one of the humans behind FACT's work, or about what it's like to be a tax professional in the policy sector, this profile is for you.

From Our Members and Allies

Antiquities Coalition: Examining Russia's assault on Ukraine's cultural heritage

On August 5th, the Antiquities Coalition, an anti-cultural racketeering group and FACT member, co-hosted an event with the Atlantic Council announcing the latest top object on their Ten Most Wanted Antiquities list: a Ukrainian artifact from Mariupol that disappeared during Russia's full-scale invasion of Ukraine. Russia currently displays the artifact in a propaganda exhibit to bolster its claim over Ukraine's land and history.To learn more about how illicit financial flows in the art market threaten U.S. national security, see this fact sheet from Transparency International U.S.

Blood Money Media: "How Trump & Musk Quietly Reopened a Trillion-Dollar Dirty-Money Loophole"

Watch a new documentary by Blood Money Media highlighting some of the major consequences of the rollback of the Corporate Transparency Act.

The documentary outlines how cartels and U.S. adversaries exploit shell companies to launder their dirty money, and how the Treasury's decision to cease enforcement of the CTA for domestic entities enables these bad actors. It also features comments from Scott Greytak and Gary Kalman, Director of Advocacy and Executive Director of Transparency International U.S., respectively.

Oil Change International: Paying for Climate Chaos - U.S. Federal Subsidies for Fossil Fuel Production

A new report from Oil Change International reveals the scope of federal subsidies for the fossil fuel industry, finding that the federal government currently hands oil and gas producers an estimated $34.8 billion annually.

From the report: "This yearly figure continues a decades-long escalation of public support for the fossil fuel industry, despite the trillions in profits accumulated by the oil and gas industry and a laundry list of harms caused by fossil fuels to the residents of this country and the globe."

Institute on Taxation and Economic Policy: Corporate Tax Transparency's Disappearing Act

Read ITEP's latest blog post reacting to a House bill that would defund the Financial Accounting Standards Board over new corporate tax reporting rules.

From the blog: "At the request of investors, FASB unveiled new accounting standards requiring companies to publicly break down their tax payments by jurisdiction...[lawmakers] are holding FASB hostage in exchange for nixing the standards update in their most recent funding bill."

Oxfam: The Most Hopeful Economic Story That's Not in the News

A new blog from Oxfam highlights the start of negotiations on a new tax convention that promises to improve global tax rules and help countries raise the revenues to provide basic necessities to its citizens.

From the blog: "That the very richest people and largest corporations too often pay too little to nothing in tax is increasingly well-understood--and an entirely man-made travesty that can be fixed. It's not right for billionaires whose wealth is surging to pay just 0.3% in taxes while 3.7 billion people live in poverty. Fixing this injustice and raising vital revenue is the driving ambition behind the push for a new tax convention."

Recent and Upcoming Events

August 6: Global labor roundtable at the UN tax negotiations in New York

During the first U.N. negotiations on a global tax convention, FACT Policy Director Zorka Milin joined global union leaders from the United States, Ghana, Kenya, Chile, Honduras, and Sweden in a constructive dialogue with senior U.N. delegates from Chile, Czechia, Germany, and the European Commission. Labor representatives were united around three core demands: taxing multinationals in line with economic activity, state-to-state tax dispute resolution, and mandatory public country-by-country reporting.

August 14: Climate Talk - Amazonia bajo amenaza

On August 14, Julia Yansura spoke at an event in Bogota hosted by the Fundacion para la Conservacion y Desarrollo Sostenible, on illicit economies threatening the Amazon region.

The event, themed around security in the Amazon, urged countries to consider & address the role of organized crime at the Amazon Summit in August, and featured speakers from government and civil society.

Wilton Park Illicit Finance Dialogue

Ian Gary, FACT's executive director, traveled to the U.K. at the beginning of September to provide expert input to the U.K. government regarding plans for an illicit finance summit in 2026. The Wilton Park Illicit Finance Dialogue, sponsored by the Foreign, Commonwealth, and Development Office, brought together government officials, civil society and academic experts, and private sector representatives to discuss ways the U.K. could tackle illicit finance, both at home and abroad.

September 29- October 1: Exposing Environmental Crimes: Online Training for Journalists and Communication Professionals

From September 29th to October 1st, FACT will co-host a specialized training to equip journalists and communication professionals with the tools to investigate environmental crime, in collaboration with the United Nations Interregional Crime and Justice Research Institute and the Nature Crime Alliance.

Journalists are on the frontline of the fight to expose environmental crimes that fuel corruption and devastate ecosystems. This free training will empower participants to follow the money, trace criminal networks, and report with accuracy and integrity through evidence-based storytelling that drives accountability.

October 13-14: A climate for change: Towards just taxation for climate finance

Next month, FACT policy director Zorka Milin will speak at a Tax Justice Network-hosted event at the University of Campinas in Brazil, which will also be livestreamed. The event will bring together advocates, policymakers, researchers, and grassroots movements from across the world to build common strategies to connect climate and taxation. The conference aims to set out a vision where countries can exercise their rights to tax fairly, reclaim the resources lost each year to tax abuse, and direct them towards development and climate priorities defined by their people. Milin's remarks will focus on the U.S. tax subsidies for fossil fuel production, and preview a new FACT report on U.S. tax subsidies for drilling abroad by multinational oil and gas companies.

About the FACT Coalition

The Financial Accountability and Corporate Transparency (FACT) Coalition is a non-partisan coalition of more than 100 state, national, and international organizations working toward a fair and honest tax system that addresses the challenges of a global economy and promotes policies to combat the harmful impacts of corrupt financial practices.

For more information, visit www.thefactcoalition.org

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