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Russian sanction-dodgers, Chinese gangsters & Mexican cartels

The full-scale invasion of Ukraine happened more than three years ago, which means full-scale Western sanctions on Russia did too. Concurrently, Russians have had just as long to figure out ways to dodge those sanctions, and I fear Western countries are being a bit too slow in realising quite how good they’re getting at it.

So, props to Transparency International’s exiled Russian chapter for this excellent report on the new laundromat, which has grown out of the Garantex crypto exchange that was shut down in April after a multi-year, multi-country effort. There is something grimly depressing, if inevitable, about the fact that within days of Garantex being snuffed out, it had been reborn. 

“It reemerged under new names, such as MKAN Coin, Grinex, and Exved, morphing into a decentralised laundering system sustained by technical obfuscation and governments’ tolerance,” TI-Russia notes. “Entities tied to Garantex continue operating across UAE, Brazil, Kyrgyzstan, Spain, Thailand, Georgia, Hong Kong, and Russia.”

Powered by the encrypted messaging app Telegram, the skilled launderers behind Garantex’s successors are learning to mitigate their vulnerabilities, rather like bacteria evolving in response to antibiotics. And they have found helpful new hosts, particularly in Kyrgyzstan. 

The rouble-pegged stablecoin A7A5 is, according to Chainalysis, operational largely in office hours, which suggests it is operating more like a shadow bank than the kind of cryptocurrencies beloved of speculators in the West. By the end of July, more than a billion dollars’ worth of transactions were moving through A7A5 every day, with it being used as a bridge between roubles and the dollar-backed cryptocurrency Tether, adding a layer of obfuscation that helps to obscure connections between Russian sanctions-busters and the big crypto operators.

There is nothing too surprising about this: money launderers have nimbly adjusted to limits on their activities ever since there have been attempts to limit those activities. In many respects, the way that Garantex’s successors have spread across jurisdictions, taking advantage of mismatches between legislation and law enforcement capabilities, is just a digital-age copy of the way the drug cartels’ bankers operated in the Caribbean in the 1980s.

Nonetheless, it is depressing that Western governments appear not to be learning as rapidly as their adversaries, and instead are relying on the blunt instrument of sanctions, rather than engaging more proactively with the causes of the problem. This is not to say that sanctions do not have their uses. They are obviously useful as a first step, and clearly very irritating to kleptocrats, otherwise they wouldn’t fight so hard to overturn them. 

For instance, Viktor Yanukovych, the corrupt former president of Ukraine whose disastrous tenure sowed so many of the problems that are causing death and misery today, has been fighting to cancel European Union sanctions against him for more than a decade. He’s now failed to have the courts overturn those sanctions, as has his son, which is wonderful. Yanukovych always seemed to have a tenuous grasp on reality, and this is nowhere more in evidence than in the apparent plot to reinstall him as president of Ukraine after the Russian full-scale invasion, which is detailed in the court’s judgement. The idea that anyone in Ukraine wanted him back goes way past self-confidence and deep into the territory of profound delusion. A weird but true aside: Yanukovych’s press secretary once bit me on the arm to prevent me asking him a question about a ludicrous inconsistency in a speech he’d just made; it was very painful, and very effective.

CHINESE GANGS & MEXICAN CARTELS

Much of the early structures used by money launderers were created in the 1950s and 1960s to serve wealthy people looking to dodge the era’s strict capital controls and high taxes. Just as today, it is the desire of wealthy Chinese people to evade capital controls that drives innovation and growth in money laundering methods.

“Chinese money laundering networks are global and pervasive, and they must be dismantled,” said FinCEN Director Andrea Gacki. “These networks launder proceeds for Mexico-based drug cartels and are involved in other significant, underground money movement schemes within the United States and around the world.” 

The core of the system is that Mexican cartels are earning huge amounts of cash dollars, which they are unable to pay into banks. So they hand them over to Chinese gangs, which in turn sell them to wealthy Chinese people looking to spend in the West. The circle is completed by the Chinese gangs shipping counterfeit goods, precursor chemicals or other things that the Mexicans need.

FinCEN has issued an advisory with guidance on what Chinese Money Laundering Networks look like, which makes very interesting reading, especially its long list of “red flags”, each one helpfully illustrated by an actual red flag. The trouble of course for the U.S. authorities is that most of the action happens outside their oversight.

With one exception: the White House could always seek to limit the printing of cash dollars that are the lifeblood of the whole system. At the very least, it could stop printing so many of the super-convenient $100 bills. But it’s not doing that. On the contrary, the value of dollars in circulation hit a new all-time high in July.

TAKING BACK ILL-GOTTEN GAINS

Among the curious folkways of British politics is that TV dramas have far more impact on political discussion than even the most considered bit of journalism. Misha Glenny’s book, McMafia, came out in 2008 and received excellent reviews for its forensic analysis of organised criminality. But it was only when a TV drama of the same name appeared a decade later that U.K. politicians woke up to London’s central role in laundering the world’s criminal wealth. 

They nicknamed a new legislative proposal “the McMafia law”, and promised it would drive kleptocratic wealth out of London. Spoiler alert: life is not a TV drama, and there was no happy ending. Lawyers fought back, and the impact of the Unexplained Wealth Order was limited.

But, wait, what’s this? The Serious Fraud Office has used an Unexplained Wealth Order to confiscate a 1.1 million pound house! So there is life in the old law yet. Granted the target was not a kleptocrat, but a fraudster; the house was not in London, but in the Lake District; and 1.1 million pounds is a rounding error compared to the 100 billion pounds or so of criminal wealth estimated to pass through the UK financial system every year. But a win’s a win, and they deserve congratulations. “Unexplained wealth orders offer investigative opportunities to pursue assets on behalf of victims and taxpayers. This is our first successful use of this legislation and it certainly won’t be the last,” said Nick Ephgrave, Director of the Serious Fraud Office. Hooray for that.

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Criminal dollars, Trump’s crypto trapdoor, and Dalek solicitors

There has been much speculation in financial circles that the White House’s erratic policymaking, random tariffs, and general shoot-from-the-hip approach could undermine the global role of the dollar, which could perhaps be replaced by the euro. I have no insight into that but I am confident that Europe’s single currency won’t replace greenbacks as criminals’ favourite money laundering tool any time soon.

Ordinary people are using cash money less and less in everyday life, so logically the amount of banknotes in circulation should be falling. Particularly at a time of high inflation, when a non-interest-bearing form of money is losing value all the time. This is what is happening in the eurozone, where the value of cash in circulation hit its all-time high in June 2022 of €1,602.6 billion, which was €16.2 billion more than the total today.

In the United States, on the other hand, the total number of dollars in circulation hits a new high every month, and in July reached $2,399.538 billion. That is an increase of $121.6 billion since June 2022, or just over five percent. The only people willing to hold paper currency when inflation is high are people who have a compelling reason not to care, and I think the only significant group of people that meet that requirement are criminals who seek anonymity. 

So while financial markets may find an alternative to the mighty dollar, at least the United States can count on the continued custom of the world’s criminals. Interestingly, the pound is behaving more like the dollar than the euro, with the total in circulation having increased by 5.9 percent since June 2022 to £93.6 billion. And the same is true of the Canadian dollar (up three percent). So I suppose an alternative explanation is that criminals just like speaking English?

BANKS CAN’T CLOSE CRYPTO BACKDOOR 

Of course one of the drivers of the dollar’s supposed decline is America’s geopolitical rivals creating new payment mechanisms outside of the Western system. Iran, under severe sanctions, has sought to create new routes for money to flow and the United States – including as recently as last week – has tried to stop that from happening.

“As a result of President Trump’s maximum pressure campaign and increasing isolation from the global financial system, the Iranian regime is running out of places to hide,” said Secretary of the Treasury Scott Bessent. “Treasury will continue to disrupt Iran’s schemes aimed at evading our sanctions, block its access to revenue, and starve its weapons programs of capital in order to protect the American people.”

Meanwhile, Trump has signed an executive order stopping the previous practice of encouraging banks from being highly sceptical of crypto clients, much to the delight of said clients. “It used to be that corresponding banks in the US block transactions involving crypto (fiat for buying crypto). This opens banking for crypto internationally,” tweeted Changpeng Zhao, founder of the giant Binance exchange.

But what does this mean for Iran? Iranians were already using crypto to evade sanctions, despite efforts by some of the better-connected companies to keep a lid on them.

“Iran’s government maintains extensive control over the country’s financial system, including cryptocurrency infrastructure,” concluded Chainalysis in an analysis published earlier this year. “Cryptocurrency represents an alternative financial system, and the increasing use of Iranian crypto exchanges suggests that more individuals and institutions are resorting to crypto to safeguard wealth and circumvent financial restrictions.”

I’m struggling to think of an analogy for what the U.S. government is doing here in its policy towards Iran’s illicit financial flows. By sanctioning the Cross-Border Interbank Messaging System used by Iranians, it’s shutting the door, but by banning U.S. banks from doing due diligence on crypto companies, it’s demolishing the wall. 

AN ATTACK OF CONSCIENCE

British real estate has been the investment of choice for kleptocrats for years, thanks to the country’s toothless regulators, conscience-free lawyers, and biddable politicians. But the war in Ukraine created much soul-searching in Britain about what exactly its approach had enabled, and a long-overdue re-examination of the system finally began, with – apparently – actual real-world consequences.

“British lawyer Rory Fordyce has been ordered to pay £32,500 for failing to adequately vet funds linked to the family of Azerbaijan’s former security chief,” reports the Organised Crime and Corruption Reporting Project (OCCRP). “In addition to the fine, Fordyce was barred from holding any legal management or compliance roles for five years and was ordered to pay £50,000 in legal costs.” And as if that wasn’t enough for the Solicitors Disciplinary Tribunal, a specialised court that brings cases against certain kinds of lawyers, it has also decided to prosecute another lawyer for making threats against people criticising the huge Ponzi scheme OneCoin, after detailed allegations were made by the Tax Policy Associates.

“Solicitors aren’t Daleks. We have ethical and professional obligations. We’re not permitted to act for an obvious fraud and threaten people who call out the fraud,” said TPA founder Dan Neidle.

The lawyer in question – Claire Gill of Carter-Ruck – denies any wrongdoing, and Carter-Ruck has promised to mount a vigorous defence. Still, hopefully this will encourage lawyers to be more diligent in checking the bona fides of their clients.

THIEVING OLIGARCHS

I’m sure many of the readers of this newsletter have read Richard Wilkinson’s and Kate Pickett’s ‘The Spirit Level’, published in 2009, with its thorough and convincing analysis of why inequality is bad for individuals and societies. I remember reading it at the time and thinking it could change the world but sadly that does not seem to have happened. 

Now Pickett is back with a series of blogs for the London School of Economics, starting with powerful posts on the environment, and health. There’s so much to think about in the global debate around oligarchy, and it’s easy to forget that it’s all about ordinary people’s lives, and how they are stunted when others cheat them of what should be theirs. 

“The picture is as tragic as it is clear regarding the gap between rich and poor and how this connects with myriad physical and mental health conditions,” she writes. “Countries with higher levels of income inequality are associated with higher rates of adult obesity and child overweightness, diabetes, mental illness, asthma, drug use and infant mortality.”

A version of this story was published in this week’s Oligarchy newsletter. Sign up here.

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A Crypto-fueled Crash, How Blockchain Blunts Sanctions & MBS’ Folly

There are now several books about the 2007-8 financial crisis, the best of which, in my opinion, is Adam Tooze’s ‘Crashed’. But the one that everyone remembers is Michael Lewis’s ‘The Big Short’, later made into a movie starring Christian Bale, Ryan Gosling, Steve Carell and Brad Pitt. Its narrative of misfits spotting the mistake everyone else was making is pleasing and elegant, so it’s easy to see why it’s so popular. 

Sadly, however, it’s completely wrong: bankers didn’t sell insanely risky financial instruments because they misunderstood them, but because the trade was profitable, and they didn’t care if they might blow up the world. 

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And this brings me to some recent headlines in the FT – “Companies load up on niche crypto tokens to boost share prices” and “Crypto lenders dial up risk with ‘microfinance on steroids’” – which have very strong pre-2007 energy. Anyone with a brain knows this will end up in disaster, but folks with money want to keep dancing while the music plays, particularly as the United States has cranked up the volume.

“When President Trump took office in January, he promised to make America the ‘crypto capital of the world’. Today, the President’s Working Group on Digital Asset Markets is releasing a report that provides a roadmap to make that promise a reality,” pledged the White House last week in a new strategy document

Perhaps the idiocy of this strategy can be best understood by pointing out its reference to “Operation Choke Point 2.0”, a confected scandal named after another confected scandal. The reason banks denied services to crypto companies is because cryptocurrencies are frequently used to enable, commit and spread financial crime, so it was an entirely sensible decision. And yet here’s the White House repeating the branding dreamt up by lobbyists to claim it was some kind of campaign against free speech. Crypto, of course, being the answer to the alleged erosion of freedoms.

The crypto boom may in fact be worse than the mortgage-backed feeding frenzy that preceded 2007-8, because the technology is not just setting us up for a new crash but freeing civilisation’s enemies from the few checks upon them. 

BOOSTING FRAUD WITH BLOCKCHAIN

Back in May, FinCEN designated Cambodia’s Huione group as being of “Primary Money Laundering Concern”, to reflect its role as the epicentre of fraud in Southeast Asia. Once upon a time, a designation like that was enough to kill a dirty bank (such as Latvia’s ABLV). But for a marketplace that lives on Telegram and trades on the blockchain, it appears to make little or no difference. “Transaction data shows no meaningful decline. In fact, our data shows continued or even increased activity,” concluded Chainalysis about Huione’s fortunes.

Meanwhile, the rouble-denominated stablecoin A7A5 is transferring more than a billion dollars’ worth of value a day, in what is becoming a magnificently successful sanctions evasion scheme that dodges any possible controls. And that’s before we come onto the “coin swap services” that allow criminals to move value around without encountering any responsible nodes in the crypto system at all.

“A sizable proportion of the $3.6 billion in illicit and high-risk funds flowing through coin swap services originates from darknet markets, ransomware, credit card fraud, hacks, Russian military fundraisers operating in Ukraine, and online gambling. A significant proportion also relates to sanctioned activity, including North Korean money laundering,” notes Elliptic.

When I was in Washington DC a few months ago I had several troubling conversations with crypto people, who were distinguished above all by their complete refusal to accept the existence of any downsides to the spread of blockchain technology, or any benefits to the traditional financial architecture based around banks it would replace. I am, as anyone who has read my books will know, no fan of banks but governments are really going to miss the ability to monitor, control and block the movement of money when it’s gone.

SANCTIONS OVERREACH

Of course, the uneasy secret underlying most anti-money laundering policy is the amount of discretion it gives governments to poke around in our private lives, and how little right we have to appeal against it (this is what the original Operation Choke Point,, and the frustration around it, was about). We are therefore rather dependent on politicians not abusing these powers for their own ends. Which is unfortunate in the circumstances.

“Alexandre de Moraes has taken it upon himself to be judge and jury in an unlawful witch hunt against U.S. and Brazilian citizens and companies,” said Secretary of the Treasury Scott Bessent, in a statement announcing sanctions against the Brazilian judge who’s investigating former President Jair Bolsonaro on charges of attempting a coup.

There is a grotesque irony in the fact that these misguided sanctions are being enacted using the Sergei Magnitsky Act, which is intended to punish corruption and human rights abuses. Perhaps the lesson we need to learn is that there needs to be better oversight of all the powers we give to our governments. 

Considering the decades-long disastrous consequences caused by well-intentioned but badly-designed anti-money-laundering policies – not least the wholesale exclusion of Muslim charities from the banking system – this could end up being a good thing. Just looking for a silver lining here.

A DYSTOPIC DREAM DIES?

I was listening to ‘In the Studio’, the excellent BBC podcast, when what should pop up but an episode on Neom, the ridiculous linear city concept apparently inspired by the 1997 Bruce Willis movie ‘The Fifth Element’, though without the punkish charm. In case you haven’t heard of Neom, it’s “an experiment in urban living”, which will extend two parallel lines of mirrored skyscrapers across 100 miles of Saudi desert, an idea so hellish that even JG Ballard would surely reject it out of hand.

Anyway, it appears the government in Riyadh has realised that spending a trillion dollars or more on some architectural fever dream might be a bad idea. “They’re finally starting to make financially sound decisions,” a consultant told CNBC.

I have been slightly obsessed with Neom for a while, and my (least) favourite bit is always when the architects wax lyrical about Mohamed bin Salman – the delicacy of his vision, the profundity of his understanding – and then clam up as soon as someone asks whether it’s right for his government to sentence people to death for resisting eviction from their ancestral homes so this horrific new city can be built. 

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Ukraine clamps down on anti-corruption activists

No one becomes an anti-corruption activist to make money, least of all in Ukraine. When I first met the co-founders of the Anti-Corruption Action Center – Vitaliy Shabunin and Daria Kaleniuk – back in 2014, they were already veterans of state persecution, and have become only more experienced in the decade since.

AntAC has pioneered and pushed through many of the reforms that have helped Ukraine to become more transparent and less corrupt, leading to the creation of new courts, new laws, new law enforcement agencies, and much more. And this is why it is so alarming that Shabunin has been arrested and his home searched, on the transparently absurd premise that he was dodging military service, while he was following an order from his superior officers to be seconded to the National Agency for Corruption Prevention.

“We strongly believe that, in addition to illegal persecution, these searches are an attempt by the authorities to obtain information about the Anti-Corruption Action Centre’s activities,” said the AntAC. “The goal is simple – to undermine our activities aimed at exposing government corruption.”

It is easy to condemn corruption by your opponents, but sadly easy to excuse it in your friends, particularly in wartime. AntAC’s consistent refusal to go easy on anyone – for example, over the government’s recent refusal to follow the law over the leadership of the Economic Security Bureau of Ukraine – has won it many enemies, but even its critics recognise how central it has been to Ukraine’s democratic development.

“The actions of the pre-trial investigation bodies can be considered either as complete incompetence of officials and unsuitability for their positions, or as a deliberate attack aimed at putting pressure on Vitaliy Shabunin, who continued to criticise the work of state bodies while serving in the military,” said 90 Ukrainian NGOs in a joint statement. 

Western foreign officials need to raise Shabunin’s case with their Ukrainian counterparts and continue raising it until this case is dropped. If Ukraine wants to keep receiving support as a democracy fighting a dictatorship, it needs to keep acting like a democracy, and that means its leaders being willing to hear things they don’t want to hear.

THE U.S., A CRYPTO-POWERED TAX HAVEN?

So the European Union’s Anti-Money Laundering Authority is up and running, and one of its first acts has been to warn about the risk posted by cryptocurrencies in its 2025 work programme. Bruna Szego, AMLA’s chair, added that national regulators need to regulate crypto companies as stringently as they do anything else, and that big crypto companies were likely to be among the 40 institutions that AMLA will directly supervise, along with the continent’s largest banks.

The view from the UK is similar. “The risk of money laundering through cryptoassets has increased significantly since 2020 with cryptoassets increasingly appearing in money laundering intelligence over this period. Cryptoassets are increasingly used for laundering all forms of proceeds of crime,” states the country’s newly-published money laundering risk assessment. “The international nature of the blockchain and cryptoasset transactions present unique difficulties in conducting effective enforcement against criminal actors.”

For anyone with a passing acquaintance with money laundering, all of this is completely non-contentious. However, it is hard to square this caution with what’s happening in the United States. Trump’s own crypto company is expanding its business, U.S. regulators are now cool with retirement accounts holding crypto, and yet another big crypto firm is looking to sell shares on the stock exchange. The technology’s boosters are feeling confident, and presenting blockchain as central to national security.

I see cryptocurrencies as near perfect tools for criminals and tycoons to escape the rules democracies put in place to prevent them from owning everything and bribing everyone. But I can also appreciate the artistry of the efforts of the Digital Chamber to boost its members’ business interests by arguing that they’re for the good of the United States and therefore for the good of humanity (for are those two causes not one and the same?).

“It is TDC’s position that blockchain technology supports global economic freedom by empowering those who resist tyranny around the world,” said the Chamber, one of the biggest crypto lobbyists in Washington, DC.

I don’t know what’s worse: that people say this stuff without believing it, or that they actually believe it. Being able to move money in secret may theoretically empower everyone, but in reality it disproportionately empowers already rich people. The U.S. is turning itself into a blockchain-powered tax haven at any incredible rate. Cartels, kleptocrats, oligarchs, spies, plutocrats, these are the real long-term beneficiaries from cryptocurrencies, and if we don’t realise that soon then the rest of us will pay a heavy price for Washington’s capitulation to their lobbyists.

THE U.K., TWO STEPS FORWARD, ONE STEP BACK

Britain, meanwhile, continues its inch-by-inch progress towards a less dirty financial system. It has dissolved 11,500 companies that did not abide by newer, more stringent rules around transparency, closed three company formation agents, and barred several people from working in corporate formation again. For those of us used to how appallingly lax things used to be, this is all rather good to see, if hard to believe (they do, after all, have previous when it comes to boasting about things they shouldn’t be proud of).

The government is planning a summit on countering illicit finance which, coupled with a surprisingly good-looking series of proposals for getting dark money out of politics, feels weirdly hopeful for a country with a tendency to err on the side of letting dirty cash go wherever it likes. I anticipate that counterbalancing bad news will be along next week.

Still, while I’m being optimistic, I’ll give a shout out to The Latimer Network, which brings together experts and practitioners in countering illicit finance from the U.K. and beyond, with the aim of improving how that is done. One of its particular focuses is on trying to think of a better way of identifying money laundering than the current workhorse: the Suspicious Activity Report (SAR). 

Tens of millions of SARs are filed globally each year, supposedly to alert the authorities to transactions that look dodgy. That is far too many to read, and most of them are valueless anyway, and it would be great to come up with a better way of monitoring transactions, so that criminals are excluded from the financial system. And don’t tell me it’s blockchain.

However, if you’d like an insight into some of the problems facing the British government, here’s a piece I wrote on the absolute disaster that is the national water system. You wouldn’t have thought you could mess up the water supply in a country where it rains so much, and yet, here we are.

A version of this story was published in this week’s Oligarchy newsletter. Sign up here.

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Lawless in Saipan, and Trump pardons crypto bros

I visited the Commonwealth of the Northern Mariana Islands a couple of years ago, intrigued by its curious bad luck in repeatedly being struck by massive gaming and money laundering scandals, like this one and this one. In case you’re not au fait with the CNMI, it’s a US territory north of Guam, which is best known as the place the Enola Gay and the Bockscar departed from on their way to drop atomic bombs on Hiroshima and Nagasaki.

It's also the current home of Jim Kingman, a Texan lawyer who was invited to the commonwealth in 2023 to act as special prosecutor in a baroque corruption scandal featuring former ex-Governor Ralph Torres, who had been acquitted along party lines in impeachment proceedings in the islands’ senate the year before.

A LESSON FROM SAIPAN

And for Kingman, it’s been basically downhill from there. His attempts to investigate, subpoena or prosecute have been frustrated at every turn by a local elite that’s decided it doesn’t really want him to make any progress. “Where are the feds? Where is the oversight? Where are the ethics committees? Where is the bar? What are we even doing out here?” he asked in a fed-up Facebook post, a year into the corruption trial, with almost no progress made.

With the change in government in Washington, DC, Kingman is clearly concerned about the future of his mission on the islands, and has given an interview to a local journalist who also described the sheer extent of obstruction that Kingman has faced. It’s a bitter read, but it has a defiant tone, a commitment to fighting corruption, that leaves an optimistic aftertaste.

“One promise that I can make is that I won’t quit,” Kingman said. “I can’t promise the desired results in a process I don’t have control over. There is a fundamental change that needs to happen to set up a more sustainable government and that will have to come from the people here. The forces that I have been facing have made it clear that these changes will not be received from an outsider.”

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Kingman is just doing his job as a lawyer, but the reason I single him out is that he’s looking pretty unusual among American lawyers at the moment. Faced with hostile politicians, Kingman is choosing to fight. Far better paid, better networked and more powerful lawyers than him are choosing to take a different route and roll over when threatened. 

I’m glad Kingman is sticking to his principles, and wish him luck. If anyone hasn’t read about what Pakistani lawyers did over a decade ago to preserve judicial independence in the face of an interfering autocrat, I highly recommend this piece. Faced with far tougher circumstances than those confronting New York’s white-shoe firms, Pakistan’s lawyers and judges took their struggle to the streets and found that most people are sympathetic to the idea of an independent judiciary that can act as a constraint on a dictatorial, power-hungry executive.

SLOW PROGRESS

Of course, lawyers can take to the streets. But the authorities’ chronic neglect of offices that investigate and prosecute corruption and financial crime has critically hampered their effectiveness. 

The U.K. non-profit “Spotlight on Corruption” has produced a really useful dashboard to track how the British authorities have fared in their efforts against financial crime. Long story short – it’s been pretty bad. If anyone needed proof that underfunding investigative agencies for years and years was an ineffective way to tackle complex criminality, then here it is.

And more evidence has been provided by Transparency International UK’s Ben Cowdock who has produced a fascinating summary of the progress the British authorities are making in reforming its corporate registry. Long story short – it’s not going very quickly. 

With an assessment by the Financial Action Task Force (FATF) on the horizon, the “pressure is on to get Companies House reform right,” Cowdock notes. The FATF sets international standards for tackling money laundering and runs mutual assessments of its members on a regular timetable, and the UK is due to be assessed in December 2027. Before that, however, in February 2026, will be the assessment of the United States and there could be fireworks.

MADE EVEN SLOWER

Donald Trump has just pardoned a corporation for the first time. He decided to cancel the judgement against the founders of a crypto trading company that was fined $100 million last year. Authorities said the fine reflected the expectation that the digital assets industry “takes seriously its responsibilities in the regulated financial industry and its duties to develop and adhere to a culture of compliance.” But Trump appears to have given up on enforcing corporate transparency, which is a central pillar of the FATF’s approach to tackling illicit finance.

“What the getaway car is to a bank heist, the anonymous company often is to a fraud scheme,” said Transparency International U.S. in this useful factsheet of cases in which American shell companies have enabled fraud and financial crime. The Trump administration’s response to this has been to not only do nothing, but to stop what was already being done. There has not yet been a time when the American government has so egregiously flouted the FATF’s core principles. And the U.S. was central to crafting FATF back in the late 1980s, so we are drifting into uncharted and rocky waters. It's hard to imagine the FATF approving of what’s happening, and harder to imagine this White House reacting well to being criticised, so you’d hope the FATF is preparing for the fallout. 

If it is, however, it’s not showing any sign of being ready for battle. Its most recent publication is almost aggressively dull. And the latest public pronouncement from its president suggests that, while she might have some thoughts about the arrangement of the deckchairs, she’s not got much to say about the iceberg up ahead.

I am personally not a huge fan of the FATF, which has been very good at producing documents and very bad at stopping money laundering. In fact, I sometimes wonder if money laundering experts aren’t the modern day equivalent of the self-perpetuating lawyers lampooned by Charles Dickens in “Bleak House”. “The one great principle of the English law is,” Dickens wrote, “to make business for itself.” Still, we might find we’ll miss the FATF if it’s gone. 

AND FINALLY, WHAT IS A KLEPTOCRACY?

I was in Oxford last Thursday to chair an event for Professor John Heathershaw and Tom Mayne, two of the authors of Indulging Kleptocracy, a book about how British professionals have helped foreign thieves and crooks to steal, keep, protect and spend their fortunes. The week before I was in Washington and had lunch with Jodi Vittori, professor at Georgetown University, and author of this recent piece in Foreign Policy headlined “Is America a kleptocracy?”.

These are noted experts on kleptocracy, with lots of very interesting things to say, but they have different definitions of what the word means. In the U.K., Heathershaw and Mayne use it to describe the multinational networks that allow corrupt officials to steal money from places like Nigeria or Kazakhstan, launder it offshore, and spend it in London, the French Riviera or Miami. In the United States, however, Vittori and Casey Michel use it to describe a system of government (like a corrupt version of autocracy, democracy or any other -cracy).

I think these two definitions are the sign of something quite interesting. The United States has so much diversity in terms of how wealth is treated between individual states that crooks and thieves are able to build a kleptocracy within just one country. And the task just became easier, with a specialized team at the Justice Department investigating kleptocrats’ deals and assets now deemed unnecessary by the Trump administration. Not entirely surprisingly, the team’s investigations had irritated some of Trump’s closest advisors and allies.

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A crypto government for a crypto nation

Last week I attended a crypto conference in Washington, D.C., and can report back that things are changing fast. New regulations look certain to come through in a hurry and – judging by the heinous quantity of lawyers in the venue – a lot of people are very serious about making a lot of money from them. This is, in my opinion, not good.

Crypto people complained bitterly under the Biden administration that regulators were treating them unfairly, by restricting their ability to do business. Many observers pointed out that crypto people were being regulated exactly the same way as everyone else, and that the reason they were struggling was that their product only makes money if it can break the rules, but the crypto people didn’t agree and responded by spending over $119 million on political donations before the 2024 elections.

MONEY WELL SPENT

The lobbying has paid off. Victorious (and well-funded) Republicans have responded to the crypto industry with a degree of enthusiasm that is positively overwhelming. Supposedly dead under the Biden administration, crypto has been brought back to rude health. “I'm so excited for all of us,” said House Majority Whip Tom Emmer. “This has been a long road to get here. We are on the precipice of actually making this happen. And guess what? That's only the beginning.”

He said Congressmen and senators were determined to get a bill onto President Trump’s desk by August that would regulate the stablecoin industry, thus providing the kind of legal certainty that would allow these “digital dollars” to explode even more dramatically than they already have. A lot of this will be overseen by the Office for the Comptroller of the Currency, which has already moved to scrap the cautious approach of the old days (i.e. last year).

“I’m creating a bright future for banks in America to use digital assets. Financial inclusion is the civil rights issue of our generation,” Rodney Hood, Acting Comptroller of the Currency, told a side session at the conference. “I have removed the sword of Damocles that was hanging over the head of the financial services industry.”

Millions of people lack bank accounts in the United States, and they are overwhelmingly the poorest members of society. Governments have failed to do enough to make sure everyone has access to financial services. And if crypto really could help vulnerable people access banking, then I’d be all for it, but I fear – certainly on the evidence of what I saw last week – it won’t.

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Perhaps the most alarming discussion was that concerning World Liberty Financial, the Trump family’s own crypto firm. Donald Trump Jr., beamed in by videolink, appeared to be seated on what looked like a white throne. He loomed over the stage like a permatanned deity in an inadequately-buttoned shirt. He explained that he’d only realised the power of crypto after his father had come out as a Republican and the family had all been cancelled. “You put that little R next to your name,” he said, explaining the need for crypto. “And I sort of realized very quickly just how much discrimination there is in the ordinary financial markets.”

The other three founders of the firm, which was created last year, all took to the stage in person. Zachary Witkoff – the son of President Trump’s special envoy tasked with helping to negotiate a ceasefire in Ukraine – spells blockchain wrong on his LinkedIn bio, and got the dress code wrong by wearing a suit and neglecting to grow a beard. Zachary Folkman, who once ran a company called ‘Date Hotter Girls’, wore a bomber jacket and facial hair, which matched the mood more precisely. Chase Herro was the most hirsute and casual of the lot, in joggers and a white baseball cap, and he explained that they would be targeting ordinary Americans, with the aim of getting them to use crypto to buy ham sandwiches from a bodega, as well as aiming to transform the cross-border payments system with their own stablecoin – USD1. 

The idea that these four nepo man-babies would be given the keys to any kind of financial institution was alarming, but the prospect of them doing so under permissive new regulations and an administration headed by one of their dads, was terrifying. “So one of our biggest goals is to kind of bring everybody back together and realize that this is a free market and, like, let the free market dictate who survives and who doesn't, and who thrives and who doesn't,” said Herro. Trump’s sons, incidentally, have also just invested heavily in a bitcoin mining company. 

WELCOME BACK, ALL IS FORGIVEN

The pace at the conference was frenetic, and every other session seemed to have Congressmen and/or senators explaining how cryptocurrencies would do their bit to make America prosperous and grand. Even three Democrats held a side session called “keeping crypto non-partisan”. No one was listening, though, partly because all the lawyers were talking to each other in the hallway but mainly because the Republican chairs of the Senate and the House banking committees were on the main stage at the same time explaining how America would remain the world’s crypto capital. 

Crypto is Trump’s project now, and no one cares what the Democrats have to say. If you want to see how much the industry has embraced the president’s talking points, check out this comically politicized advert from the blockchain company Solana, home of the $Trump memecoin. Even on X, the backlash was so fierce that Solana had to delete it.

What does this mean for the rest of the world though? American politicians seem to have decided that cryptocurrencies – and, particularly, dollar-denominated stablecoins – are good for America, that they bring business to the country, and help find customers for the Treasury’s debt. Anything that gets in the way of crypto therefore is bad for America. With great power comes great opportunity, as Peter Parker’s Uncle Ben might have said if only he’d had more donations from a pro-crypto SuperPAC.

Bo Hines, the hatchet-faced head of Trump’s council of crypto advisers, said his message to any crypto people working offshore was: “welcome home”. 

As for Tom Emmer, even the prosecution of the founders of Tornado Cash – the software that, prosecutors say, allowed criminals including North Korean hackers to hide $1 billion of stolen wealth – was governmental overreach. “We need all that innovation, all those risk takers and creators in this country, that's what is the definition of success. From that you'll get that economic growth,” Emmer said.

There is a terrible irony that cryptocurrencies – an idea much of whose popularity stemmed from the public anger sparked by the deregulation and greed that caused the great financial crisis of 2007-2008 – are becoming a new nexus for deregulation and greed. And I worry about what the backlash will bring when this too collapses. And I worry about all the bad behaviour that will be enabled before the collapse happens.

As Corey Frayer, who served in the Securities and Exchange Commission under Joe Biden, once said: “Crypto is a machine where fraud and money laundering go in one side, and political donations come out the other end.” 

A version of this story was published in this week’s Oligarchy newsletter. Sign up here.

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