On February 6, 2018, Acting Deputy Assistant Attorney General M. Kendall Day of the DOJ’s Criminal Division testified before the Senate Judiciary Committee, which held a hearing titled “Beneficial Ownership: Fighting Illicit International Financial Networks Through Transparency.”  In his remarks, Day highlighted gaps in anti-money laundering laws that are increasingly exploited through the misuse of corporate structures, referring to the “pervasive use of front companies, shell companies, [and] nominees” as “one of the greatest loopholes” in the U.S. regime.  Day noted the dearth of state laws requiring information about beneficial ownership and the lack of a comprehensive federal-level system.  At the same time, Day praised the Treasury Department’s Customer Due Diligence Final Rule, which, beginning in May, will require financial institutions to verify the identities of beneficial owners that open accounts.

Remarks as Prepared