TFFC’s Office of Strategic Policy (OSP) consists of three teams that focus on the intersection of national security with functional sectors and issues, including international banking, securities, money services businesses, emerging technologies, corruption, charities, proliferation financing, terrorist financing, and transnational organized crime.
The Office of Strategic Policy Teams
Financial Transparency and Regulatory Policy Team
The Financial Transparency and Regulatory Policy Team (FT) focuses on systemic initiatives to enhance the transparency and integrity of the domestic and international financial systems.
- To aid in TFFC’s policy formulation and coordination work, this team continuously evaluates the U.S. AML/CFT/CPF regime, looking across the U.S. and global landscape to ensure that the U.S. regime is properly calibrated to address existing and emerging illicit finance threats, risks, and vulnerabilities. Recent initiatives include work on correspondent banking, human trafficking, corruption, and financial innovation (including Digital ID and payments, and broadening financial inclusion).
- At the international level, this team works on a bilateral and multilateral basis—including at the FATF, UNODC, G20, G7, FSB, and other fora—to develop and promote transparency and anti-corruption initiatives.
- This work includes advancing the international standards for beneficial ownership transparency and virtual assets at the FATF, which then, as appropriate, informs updates to U.S. policies and regulations; efforts to address barriers to cross-border information sharing for AML/CFT/CPF purposes, including data privacy and data localization laws; and fostering policy development to promote innovative approaches to AML/CFT/CPF issues, including the hosting of the inaugural Financial Sector Innovation Policy Roundtable.
- The team develops policy by working closely with the relevant TFI components, other offices of the Treasury, and other U.S. policy and law enforcement agencies to advance our shared objective of protecting the U.S. and global financial systems from abuse.
National Security Threats and Trends Team
The National Security Threats and Trends (NSTT) team focuses on systemic analysis and recommendations to evaluate risks and address existing and emerging illicit financial threats, strengthening the AML/CFT/CPF regimes in the United States and internationally.
NSTT, in consultation with Treasury colleagues and other federal government agencies with roles in combating illicit finance, prepares the National Illicit Finance Strategy and its accompanying National Risk Assessments for Money Laundering, Terrorist Financing, and Proliferation Financing. NSTT also works with Treasury and interagency partners on various U.S. government illicit finance assessments and reports.
- 2022 National Illicit Finance Strategy
- 2022 National Money Laundering Risk Assessment
- 2022 National Terrorist Financing Risk Assessment
- 2022 National Proliferation Financing Risk Assessment
- 2022 Study on the Facilitation of Money Laundering and Terror Finance Through the Trade in Works of Art
- 2020 National Illicit Finance Strategy
- 2018 National Illicit Finance Strategy
- 2018 National Money Laundering Risk Assessment
- 2018 National Terrorist Financing Risk Assessment
- 2018 National Proliferation Financing Risk Assessment
- 2017 Countering America’s Adversaries Through Sanctions Act (CAATSA)
- 2015 National Money Laundering Risk Assessment
- 2015 National Terrorist Financing Risk Assessment
At the international level, NSTT leads and coordinates U.S. contributions to the FATF on risk typologies, guidance, and best practices reports to include TF and PF Risk Assessment Guidance, and various risk-based guidance reports for supervisors, regulated sectors, and professionals.
The International Programs Team
The International Programs (IP) Team focuses on targeting and addressing the financial underpinning of major global threats, including kidnapping for ransom and hostage-taking, terrorist financing-related abuse of non-profit organizations (NPOs), and deficiencies in national AML/CFT/CPF regimes. IP also lends AML/CFT/CPF expertise to support the FATF’s International Cooperation Review Group (ICRG) and Evaluation Consistency and Quality process, United Nations (UN) Counterterrorism Programs, the global implementation of FATF and UN financial sanction obligations, and coordinates TFI’s outreach to the charitable sector.
Through ICRG, IP works closely with technical experts from other FATF member countries to review deficiencies in national AML/CFT/CPF regimes. Over 80 jurisdictions have gone through this FATF-led process and improved their regimes as a result. The U.S. devotes significant technical expertise to ensure quality and consistency in the process.
IP also works to further Treasury’s commitment to ensuring that legitimate humanitarian assistance flows to those in need while balancing the U.S. government’s objective to protect the NPO sector from abuse by terrorists seeking to use NPOs as a cover to raise, move, or use funds. To achieve these goals, IP works closely with the charitable sector to coordinate TFI’s humanitarian community outreach through its quarterly meetings, ad-hoc roundtables, and individual consultations.
IP also represents Treasury at the Hostage Recovery Fusion Cell (HRFC), a multi-agency team based at the Federal Bureau of Investigation that coordinates the U.S. government’s efforts to recovering U.S. nationals taken hostage or kidnapped for ransom abroad. IP also provides technical and policy expertise on terrorist financing and sanctions considerations to the Hostage Response Group, an interagency body chaired by the National Security Council that coordinates the development and implementation of U.S. government policy and strategy with respect to U.S. nationals taken hostage abroad.