IV 

116TH CONGRESS 

1ST SESSION H. RES. 206 

Acknowledging that the lack of sunlight and transparency in financial transactions and corporate formation poses a threat to our national security 

and our economy’s security and supporting efforts to close related loopholes. 

IN THE HOUSE OF REPRESENTATIVES 

MARCH 8, 2019 

Ms. WATERS submitted the following resolution; which was referred to the 

Committee on Financial Services 

RESOLUTION 

Acknowledging that the lack of sunlight and transparency 

in financial transactions and corporate formation poses 

a threat to our national security and our economy’s 

security and supporting efforts to close related loopholes. 

Whereas money laundering and other financial crimes are serious threats to our national and economic security; 

Whereas the United Nations Office on Drugs and Crime has 

reported ‘‘The estimated amount of money laundered 

globally in one year is 2–5% of global GDP, or $800 billion–$2 trillion in current US dollars’’; 

Whereas the scale, efficiency, and complexity of the U.S. financial system make it a prime target for those who seek 


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•HRES 206 IH 

to conceal, launder, and move the proceeds of illicit activity; 

Whereas money launderers, terrorist financiers, corrupt individuals and organizations, and their facilitators have 

proven to adapt quickly in order to avoid detection; 

Whereas given the global nature of money laundering and 

terrorist financing, and the increasing interrelatedness 

within the financial system, a secure national and multilateral framework is essential to the integrity of the U.S. 

financial system; 

Whereas extensive collaboration among financial regulators, 

the Department of the Treasury, law enforcement, and 

the private sector is required to curtail the illicit flow of 

money throughout the United States; 

Whereas despite how extensive and effective these efforts are 

in the United States, there is still substantial room for 

improvement; 

Whereas financial compliance, reporting, investigation, and 

collaboration, as well as courageous whistleblowers and 

investigative reporting (such as the Panama Papers) have 

had significant impact in shining sunlight on the people 

and institutions behind dark money and markets; 

Whereas in 2016, the Financial Action Task Force (FATF), 

the international standards setting body, evaluated the 

United States anti-money-laundering/combating the financing of terrorism measures and determined the 

United States has significant gaps in its framework; 

Whereas in 2016, the FATF found that in the United States, 

‘‘Minimal measures are imposed on designated non-financial businesses and professions (DNFBPs), other than 

casinos and dealers in precious metals and stones’’; 


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•HRES 206 IH 

Whereas in 2016, the FATF recommended, ‘‘The U.S. should 

conduct a vulnerability analysis of the minimally covered 

DNFBP sectors to address the higher risks to which 

these sectors are exposed, and consider what measures 

could be introduced to address them’’; 

Whereas dealers in arts and antiquities are not, by definition, 

covered ‘‘financial institutions’’ required to comply with 

the Bank Secrecy Act; 

Whereas Federal authorities have cautioned that art collectors and dealers to be particularly careful trading Near 

Eastern antiquities, warning that artifacts plundered by 

terrorist organizations such as the Islamic State of Iraq 

and the Levant are entering the marketplace; 

Whereas, according to the Antiquities Coalition, ‘‘because the 

United States is the largest destination for archaeological 

and ethnological objects from around the world, the discovery of recently looted and trafficked artifacts in our 

country not only makes Americans and our institutions 

accessories to crimes, but also threatens our relations 

with other countries’’; 

Whereas the real estate industry, both commercial and residential, is exempt from having to develop and implement 

a four-pillar anti-money-laundering program pursuant to 

the Bank Secrecy Act; 

Whereas it was asserted in a 2018 Conference Report by the 

Terrorism, Transnational Crime and Corruption Center 

at the Schar School of Policy and Government of George 

Mason University, money laundering in real estate 

(MLRE) has damaging effects on local economies by negatively impacting property prices and dislocating residents; 


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•HRES 206 IH 

Whereas in 2017, in response to evidence about significant 

money laundering through real estate in the United 

States, the Financial Crimes Enforcement Network 

(FinCEN) issued Geographic Targeting Orders (GTOs) 

requiring limited beneficial ownership disclosure in certain transactions involving high-end luxury real estate 

and ‘‘found that about 30 percent of the transactions 

covered by the GTOs involve a beneficial owner or purchaser representative that is also the subject of a previous suspicious activity report’’; 

Whereas the influx of illicit money, including from Russian 

oligarchs, has flowed largely unimpeded into the United 

States through these anonymous shell companies and into 

U.S. investments, including luxury high-end real estate; 

Whereas in a Conference Report by the Terrorism, Transnational Crime and Corruption Center at the Schar School 

of Policy and Government of George Mason University, 

stated ‘‘The lack of beneficial ownership transparency is 

the most important single factor facilitating MLRE in 

the U.S.’’; 

Whereas the lack of beneficial ownership disclosure has been 

found in several reports, such as those by the FACT Coalition and Polaris, to facilitate human trafficking, corruption, terrorism, sanctions evasions, and numerous other 

financial crimes; 

Whereas the establishment of national-level beneficial ownership registers has been adopted by other developed nations, including those of the European Union; 

Whereas in 2016, the FATF found that ‘‘Lack of timely access to adequate, accurate and current beneficial ownerVerDate Sep 11 2014 23:40 Mar 08, 2019 Jkt 089200 PO 00000 Frm 00004 Fmt 6652 Sfmt 6300 E:\BILLS\HR206.IH HR206

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•HRES 206 IH 

ship information remains one of the fundamental gaps in 

the U.S. context’’; 

Whereas the FATF recommended the United States ‘‘Take 

steps to ensure that beneficial ownership information of 

U.S. legal persons is available to competent authorities in 

a timely manner, by requiring that such information is 

obtained at the Federal level’’; 

Whereas the United States has not fulfilled the recommended 

steps to address the money-laundering loopholes that the 

FATF has identified with DNFBP sectors and the lack 

of beneficial ownership disclosure; 

Whereas high-profile enforcement actions against some of the 

largest and most sophisticated financial institutions raise 

troubling questions about the effectiveness of U.S. domestic anti-money-laundering and counterterrorism financing regulatory, compliance, and enforcement efforts; 

Whereas there are financial institutions and individuals employed therein which continue to engage in egregious violations of the Bank Secrecy Act and enter into deferred 

prosecution agreements and non-prosecution agreements 

rather than facing convictions and sentences corresponding to the severity of their violations; 

Whereas effective anti-money-laundering programs must emphasize sound corporate governance, including businessline accountability and clear lines of legal responsibility 

for individuals, including board members and chief executive officers; and 

Whereas anti-money-laundering examinations in recent years 

at times failed to recognize the cumulative effect of the 

violations they cited, instead narrowly focusing their attention on individual banking units, thus permitting naVerDate Sep 11 2014 23:40 Mar 08, 2019 Jkt 089200 PO 00000 Frm 00005 Fmt 6652 Sfmt 6300 E:\BILLS\HR206.IH HR206

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•HRES 206 IH 

tional banks to avoid and delay correcting problems, 

which allowed massive problems to occur before serious 

enforcement actions were taken: Now, therefore, be it 

1 Resolved, That the House of Representatives— 

2 (1) acknowledges that the lack of sunlight and 

3 transparency in financial transactions poses a threat 

4 to our national security and our economy’s security; 

5 (2) supports efforts to close loopholes that allow 

6 corruption, terrorism, and money laundering to infil7 trate our country’s financial system; 

8 (3) encourages corporate transparency to de9 tect, deter, and interdict individuals, entities, and 

10 networks engaged in money laundering and other fi11 nancial crimes; 

12 (4) urges financial institutions to comply with 

13 the Bank Secrecy Act and anti-money laws and reg14 ulations; and 

15 (5) affirms that financial institutions and indi16 viduals should be held accountable for money-laun17 dering and terror-financing crimes and violations. 

Æ 


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