Global Financial Integrity

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Public Comments

GFI is pleased to provide comments on proposed rulemaking, regulations, and other government or intergovernmental activities. We focus on activities that have an impact on illicit financial flows and financial transparency on the U.S., foreign, and international platforms. Here are two of GFI’s most recent public comments:

GFI Comments to FinCEN on ANPRM

Global Financial Integrity (GFI) submitted comments to the Financial Crimes Enforcement Network (“FinCEN”) of the United States (U.S.) Department of the Treasury (Treasury) in response to the advance notice of proposed rulemaking (“ANPRM”) regarding “Anti-Money Laundering Regulations for Real Estate Transactions.” GFI recognizes that the current U.S. regulatory approach of using GTOs which are temporary and location-specific were valuable in its inception. However, the GTOs policy has several shortcomings, including limitations inherent to a temporary, location specific order. GFI discusses how the GTOs cannot act as a substitute for a comprehensive rule that tackles the risk of money laundering in the U.S. real estate sector, and provides recommendations to inform new AML regulations for real estate transactions.


GFI Comments on Kenya’s The Companies (Beneficial Ownership Information) (Amendment) Regulations

Following The Business Registration service of Kenya’s (BRS) call, GFI submitted and presented comments on The Companies (Beneficial Ownership Information) (Amendment) Regulations, 2021 dated 8th December 2021. As countries act to improve financial transparency, disclosing beneficial ownership information as simple and inexpensive as possible will promote compliance and help achieve the ultimate aim of greater corporate accountability. GFI supports the initiative to adopt streamlined procedures which are important for economies as they implement new transparency policies. GFI recommended measures that address the transparency and BO of legal persons and recommendations that countries should adopt to achieve accountability.