Tell the Treasury Department by October 3rd: U.S. Banks Shouldn’t Be Used to Fund Mass Atrocities

Every day, American banks and the US dollar are being exploited by the worst of the worst. Perpetrating atrocities on a mass scale requires weapons, infrastructure, and money – heaps of it. And for those human rights abusers and war criminals who get their funding through trafficking, pillage, and corruption comes the problem of where to stash their cash.

Unfortunately, within the current legal system regulating financial institutions, it is impossible to know for sure if U.S. bank accounts are linked to mass atrocities. The Department of Treasury, however, is working to change this. A new federal regulation has been proposed, requiring banks and other financial institutions to collect information on the actual living breathing person behind accounts.

The collection of this information is necessary to combat the funding of mass atrocities and war crimes, terrorist financing and sanctions evasion as well as money laundering, fraud, and tax evasion.

The current proposed rule from Treasury, however, does not include any retroactive searches of questionable accounts or transactions, and would only apply to new accounts created starting one year after the final rules are enacted. Banks have heavily advocated in favor of this new regulation only being forward-looking, claiming that any effort to look at current questionable accounts would cost them money. But the expense by banks for this basic due diligence is well worth it. If this huge loophole is left open, the new regulations will do nothing to clean up cases where U.S. financial institutions have already been abused -- by war criminals, traffickers, terrorists, and genocidaires.

Your voice is needed by October 3rd to counter the banks, and ensure that a “look back provision” for questionable accounts is required. Comments on the Federal Register, linked to below, will let the government know directly that tracing bank accounts tied to funds for questionable activities is imperative.

Read the Proposed Regulation

Take Action: Comment Now (Link will take you to the Federal Register)

Sample Comment: (Can be copied & pasted directly, or customized. Comments can be any length.)

I am deeply concerned by the lack of oversight within the U.S. financial system for the real people behind bank accounts (the “beneficial owners”). To combat crimes such as international mass atrocities and war crimes, as well as sanctions evasion and money laundering, it is imperative for financial institutions to perform effective customer due diligence in order to know who their customers are and what transactions they conduct.

I advocate for an expansion of the current proposed rule and specifically urge you to include a retroactive look back on pre-existing accounts where there is some reason to think that there’s a risk that the account might be used to facilitate money laundering or other support for war crimes and other mass atrocities. The bank accounts that disguise involvement in illicit financial activity funding mass atrocities remain a longstanding vulnerability that facilitates war crimes. With one of the largest financial markets and as leaders in human rights around the world, the U.S. must take steps to end this. As a U.S. citizen, I am deeply committed to our responsibility to do what we can to fight these crimes around the world.

These final regulations will bring the U.S. more in line with international standards and will help ensure that law enforcement is better able to track illicit activity potentially funneling money to war criminals in the U.S. financial system.

It is imperative that the final regulations promote the strongest standards, and I urge you to include a look back at existing accounts on a risk basis.

Topics to be sure to include:

  • Please expand the rule to include a look back provision on existing accounts with reason to believe there’s risk of illicit activity
  • This is imperative for the U.S. to do its part to combat some of the worst crimes around the world today, whose perpetrators might be using American banks to store their money: money used to commit mass atrocities.

Take Action: Comment Now