May 10, 2022

Warren Leads Bipartisan Letter Urging Treasury to Swiftly Implement Corporate Transparency Act to Support Russian Sanctions

Swift Implementation of Legislation Would Upgrade Anti-Money Laundering Protections and Help Fully Impose Sanctions on Russian Oligarchs

Treasury Delays Undermine U.S. Efforts to Respond to Russia’s War Against Ukraine

Text of Letter (PDF)

Washington, D.C. – United States Senator Elizabeth Warren (D-Mass.), a member of the Senate Finance Committee, Chuck Grassley (R-Iowa), Sheldon Whitehouse (D-R.I.), Marco Rubio (R-Fla.), Ron Wyden (D-Ore.), Chair of the Senate Finance Committee, Bob Menendez (D-N.J.), and Bill Cassidy (R-La.) sent a bipartisan letter to Treasury Secretary Janet Yellen and Acting Director of the Financial Crimes Enforcement Network (FinCEN) Himamauli Das, calling on the Treasury Department (Treasury) to swiftly implement the Corporate Transparency Act (CTA) and provide a timeline for doing so. Implementation of the CTA would upgrade the country’s anti-money laundering laws and help the federal government fully impose sanctions on Russian oligarchs. But FinCEN has proposed only one of three planned CTA rules, and is now four months past the statutory deadline for implementation. 

“The Treasury Department has yet to finalize the implementation of the CTA—or even set a timetable for its completion… In various hearings last month, both of you could only commit to proposing the second CTA rule by the end of ‘this year.’ These delays run contrary to the clear instructions of Congress, undermine American efforts to respond to Russia’s war against Ukraine, and hinder broader efforts to protect the U.S. financial system against the threat of illicit finance,” wrote the lawmakers. 

Passed by Congress last year, the CTA is landmark legislation that would upgrade the country’s anti-money laundering laws and address one of the biggest weaknesses in the United States’ anti-money laundering safeguards: anonymous shell companies that hide the true, beneficial owners of assets. Beneficial ownership disclosure, as required by the CTA, is particularly relevant amidst Russia’s invasion of Ukraine since such information is necessary to implement the United States’ historic sanctions against Russian oligarchs and to protect national security and the stability of the U.S. financial system. 

The lawmakers also acknowledged that FinCEN is working with limited resources and stated that Congress is working to remedy this problem through the appropriations process.

Senator Warren is a leader in ensuring the integrity and transparency of the financial system. As the United States has led global efforts to sanction Russia and Russian individuals in response to Putin’s unjustifiable war in Ukraine, Senator Warren has worked to ensure that these sanctions are fully enforced. 

  • In April 2022, Senators Warren, Cassidy, Whitehouse, and Wicker introduced the bipartisan KLEPTO Act to strengthen beneficial ownership requirements for mansions, private jets, and yachts held in the United States.
  • In April 2022, at a hearing of the Senate Banking Committee, Senator Warren questioned a Treasury Department nominee about the importance of “know your customer” requirements for the private investment industry.
  • In March 2022, Senators Warren and Whitehouse sent a letter calling on Secretary of the Treasury Janet Yellen and Chair of the Securities and Exchange Commission (SEC) Gary Gensler to close the loophole that exempts the $11 trillion private investment industry from anti-money laundering (AML) and countering the financing of terrorism (CFT) obligations.
  • In March 2022, at a hearing of the Senate Banking Committee, Senator Warren warned that Putin and Russian elites could use crypto to hide their wealth and evade economic sanctions. 
  • In March 2022, Senator Warren and Senators Jack Reed (D-R.I.), Mark Warner (D-Va.), and Jon Tester (D-Mont.) introduced the Digital Asset Sanctions Compliance Enhancement Act of 2022, which would ensure that Vladimir Putin and Russian elites don’t use cryptocurrencies and other digital assets to undermine the international community’s economic sanctions against Russia.
  • In March 2022, Senator Warren and Senators Warner, Sherrod Brown (D-Ohio), and Reed sent a letter to Treasury Secretary Janet Yellen raising concerns regarding the potential use of cryptocurrency to evade sanctions, which have become even more urgent amid the sanctions imposed on Russia after its invasion of Ukraine.