November 5, 2009
TG-353
Written Testimony of Assistant Secretary for
Terrorist Financing David S. Cohen
Senate Committee on Homeland Security and Governmental Affairs
“Business Formation and Financial Crime:
Finding a Legislative Solution”
I. Introduction
Chairman Lieberman, Ranking Member Collins, distinguished members of the
Committee, thank you for inviting me to testify today. I am pleased to have the
opportunity to present the Department of the Treasury's views on the global
challenge of enhancing access to beneficial ownership information in order to
combat the abuse of legal entities by those engaging in financial crime.
I would like to begin by thanking Senator Levin for his leadership on this important
and pressing topic, and for raising awareness in the U.S. and globally of an issue
that is of paramount importance in our efforts to combat financial crime. I would
also like to extend my appreciation to colleagues across the government and
private sector, here at home and internationally, who have worked with the
Department of the Treasury and invested a tremendous amount of time and energy
in attempting to address the challenges of making beneficial ownership information
more readily available.
My colleagues across the Department of the Treasury, including from the Office of
Terrorism and Financial Intelligence, Domestic Finance, International Affairs and
Tax Policy, have all contributed to Treasury's thinking on how best to require the
disclosure of beneficial ownership information in a way that effectively combats the
criminal misuse of legal entities while, at the same time, ensuring that we do not
unduly complicate the company formation process, which plays such an important
role in our nation's economic prosperity. I look forward today to outlining Treasury's
approach to this critically important and difficult challenge, explaining the basis for
our current thinking, and offering the Administration's views on S. 569, the
"Incorporation Tra