Attorney General Garland: Good afternoon.
I am joined today by Treasury Secretary Janet Yellen, Deputy Attorney General Lisa
Monaco, and CFTC Chairman Russ Behnam. We are here today to announce that the Justice
Department has secured felony guilty pleas from the world’s largest cryptocurrency exchange,
Binance, and from its founder and CEO, Changpeng Zhao, also known as CZ.
Separate from the criminal enforcement actions the Justice Department is announcing
today, Secretary Yellen and Chairman Behnam will also announce civil regulatory enforcement
actions that the Treasury Department and the CFTC are taking against Binance.
While criminal and civil enforcement actions are subject to different legal
standards, this collective effort represents the whole of government approach
that we are taking to combat corporate crime. Binance has agreed to plead guilty to
willfully violating the Bank Secrecy Act, knowingly failing to register as a money
transmitting business, and willfully violating the International Emergency Economic Powers Act.
These laws ensure that our financial institutions are not available to designated
terrorist organizations, drug traffickers, and sanctioned nation-states that threaten
public safety and our national security. The Justice Department is requiring Binance to pay
$4.3 billion in penalties and forfeiture. This is one of the largest penalties we have ever obtained
from a corporate defendant in a criminal matter. The Justice Department is also imposing a
monitorship as well as reporting requirements on Binance as part of today’s resolution.
Moving forward, Binance must file the suspicious activity reports that were required
by law. The company is required to review past transactions and report suspicious activity
to federal authorities. This will advance our criminal investigations into malicious
cyber activity and terrorism fundraising, including the use of cryptocurrency
exchanges to support groups such as Hamas. While this historic plea is an important measure
of accountability, we know that corporations only act through the individuals who run them.
That is why we have also filed a felony charge against, and secured a guilty plea from, Changpeng
Zhao for willfully violating the Bank Secrecy Act. As CEO of Binance, Zhao willfully violated federal
law that requires financial institutions to guard against money laundering and terrorist financing.
Zhao, who resides outside of the United States, entered his plea in person in the
United States District Court for the Western District of Washington earlier today.
In August 2017, Zhao founded Binance as a platform where users could trade in cryptocurrency.
But from the very beginning, Zhao and other Binance executives engaged in a deliberate
and calculated effort to profit from the U.S. market without implementing
the controls required by U.S. law. Zhao and Binance attracted and built a
substantial U.S. customer base. Almost two years after Binance’s founding, Zhao told senior
management that the U.S. market represented 20 to 30% of the company’s potential revenue.
Serving these U.S. customers meant that Binance was a U.S. financial institution.
U.S. financial institutions must comply with U.S. law. Zhao and other senior
management at Binance understood this. They understood that the company was required
by U.S. law to register with the Treasury Department as a money services business.
And they understood that they were required by U.S. law to implement an effective anti-money
laundering program. They failed to do either. Instead, they concluded that complying with U.S.
law would stifle their efforts to grow Binance’s profits, market share, and trading volume.
So, rather than comply, Binance facilitated billions of dollars of unregulated
cryptocurrency transactions. It willfully enabled hundreds of millions
of dollars in transactions between American users and users subject to U.S. sanctions.
And its platform accommodated criminals across the world who used Binance to move their
stolen funds and other criminal proceeds. Binance prioritized its profits over
the safety of the American people. In part because of the crimes it committed,
Binance became the largest cryptocurrency exchange in the world. Now Binance is paying one of the
largest corporate penalties in U.S. history. Binance employees knew and discussed that
the company was serving thousands of users in sanctioned countries. And they knew that
facilitating transactions between U.S. users and users in sanctioned countries
would be in violation of U.S. law. But they did it anyway. Binance enabled nearly
$900 million in transactions between U.S. and Iranian users. And it facilitated millions
of dollars in transactions between U.S. users and users in Syria and in the Russian-occupied
Ukrainian regions of Crimea, Donetsk, and Luhansk. Binance’s own compliance personnel
also knew that the company’s anti-money laundering procedures were inadequate and
would attract criminals to the platform. In a February 2019 chat, one compliance employee
wrote that they needed a banner that said: “is washing drug money too hard these days
- come to binance; we got cake for you.” By failing to comply with U.S. law, Binance
made it easy for criminals to move their stolen funds and illicit proceeds on its exchange.
For example, between August 2017 and April 2022, there were direct transfers of approximately
$106 million in bitcoin to Binance.com wallets from Hydra. Hydra was a popular Russian darknet
marketplace, frequently utilized by criminals, that facilitated the sale of
illegal goods and services. Binance only stopped processing Hydra transactions
in April of 2022, when the Justice Department and our German law enforcement partners seized
control of the Hydra marketplace and shut it down. From February 2018 to May 2019, Binance
processed more than $275 million in deposits and $273 million in withdrawals from Bestmixer.
Bestmixer was one of the largest cryptocurrency anonymizing services in the world before
it was shut down for money laundering. Binance also did more than just fail to comply
with federal law – it pretended to comply. In June 2019, Binance publicly announced that
it would block U.S. users from Binance.com and launch a separate U.S. exchange. That exchange,
Binance.US, would register with the Treasury Department and serve the U.S. market. Binance
blocked some U.S. users on Binance.com and redirected them to the U.S. exchange.
At the same time, however, Binance continued to allow some of its most
important, high-volume U.S. users to remain on the unregistered Binance.com exchange.
At the direction of Zhao and other senior leaders at Binance, employees encouraged
their high-volume U.S. users to conceal their U.S. connections, including by creating
new accounts that obscured their locations. As Zhao himself said in a September 2019
chat: “If we blocked US users from day 1, Binance will be not [sic] as big as we are today.
We would also not have had any US revenue we had for the last 2 years.” He then added: “better
to ask for forgiveness than permission.” Over a year after Binance publicly
announced that it was blocking U.S. users, an internal monthly company report attributed
16% of its total registered user base to the United States. That was more than any other
country on the unregulated Binance.com platform. In the next monthly report, Binance removed
the United States label and recategorized U.S. users with the label “UNKWN” – short for
“unknown.” In October 2020, users labeled as “UNKWN” represented approximately
17% of Binance’s registered user base. Binance and Zhao profited significantly from
their violations of federal law. That they are facing accountability for their crimes is due
to the hard work of the extraordinary public servants at the Department of Justice.
I want to thank the Criminal Division’s Money Laundering and Asset Recovery Section; the
National Security Division’s Counterintelligence and Export Control Section; and the United States
Attorney’s Office for the Western District of Washington for their excellent work.
I also want to thank Secretary Yellen and her team at the Treasury Department,
including IRS Criminal Investigation, as well as CFTC Chairman Behnam and his team for
their extraordinary partnership in this matter. In just the past month, the Justice Department
has successfully prosecuted the CEOs of two of the world’s largest cryptocurrency
exchanges in two separate criminal cases. The message here should be clear: Using
new technology to break the law does not make you a disruptor. It makes you a criminal.
This Justice Department has no tolerance for crimes that threaten our economic institutions
and undermine public trust in the fairness of those institutions. And we will hold accountable
the individuals who commit and profit from them. I am now pleased turn the
podium over to Secretary Yellen. Treasury Secretary Yellen: Good afternoon. I’m
very glad to join Attorney General Garland, Deputy Attorney General Monaco, and CFTC
Chairman Behnam on such an important occasion. We’re here today to announce the Treasury
Department’s historic action—the largest enforcement action in Treasury’s
history—against Binance—the world’s largest virtual currency exchange—for its
consistent and egregious violations of U.S. anti-money laundering and sanctions law.
Protecting the U.S. financial system, and through that, the global financial system, is
core to the Treasury Department’s mission. And, ever since Binance launched its convertible
virtual currency platform, it has knowingly evaded the U.S. laws designed to protect these systems.
Over more than three years, FinCEN, OFAC, and IRS Criminal Investigation thoroughly investigated key
aspects of Binance’s activities. Our work revealed that Binance claimed to have exited the U.S.
market years ago, but actually did not, retaining U.S. users and other significant ties with the
United States. It also had critical gaps in its anti-money laundering program and practices,
from a lack of risk-based procedures for various offerings to instructing staff to withhold
information from law enforcement. It deliberately undermined its own sanctions monitoring controls,
and it failed to report suspicious transactions. This meant Binance was allowing illicit actors
to transact freely, supporting activities from child sexual abuse, to illegal narcotics, to
terrorism, across more than 100,000 transactions. That includes transactions associated with
terrorist groups like Hamas’s Al-Qassam Brigades, Palestinian Islamic Jihad, Al Qaeda, and ISIS.
Binance processed these transactions, but it never filed a single suspicious activity report.
And it also allowed over 1.5 million virtual currency trades that violated U.S. sanctions.
So, we have taken the largest enforcement action in Treasury’s history. FinCEN’s
settlement agreement assesses a penalty of $3.4 billion. OFAC’s settlement agreement
assesses a penalty of nearly $1 billion. Binance is also required to report the suspicious
transactions it has failed to report to date and to establish an effective anti-money laundering
program to support the global AML/CFT regime. And the settlement agreements subject Binance
to increased scrutiny for five years through a third-party monitor, overseen by FinCEN, who
will ensure Binance’s complete exit from the United States. The monitor will be able to
access Binance’s systems, transactions, and accounts and will review and report on all actions
included in the settlement agreements. Failure to live up to these obligations could expose
Binance to substantial additional penalties. The result of these agreements will be an end
to company behavior that has posed risks to the U.S. financial system, U.S. citizens, and
our country’s national security for too long. And let me be clear: We are also sending
a message to the virtual currency industry more broadly, today and for the future.
If virtual currency exchanges and financial technology firms wish to realize the tremendous
benefits of being part of the U.S. financial system and serving U.S. customers, they
must play by the rules. And if they do not, the U.S. government will take action.
Today’s announcement shows that Treasury is prepared to use all of its tools to carry
out its crucial mandate of combatting illicit finance and protecting the U.S. financial
system. And this will make all of us safer. I want to end by thanking FinCEN, OFAC, and IRS
Criminal Investigation employees, who play a central role in protecting our national security.
Adequate resourcing was critical to carrying out this work. Thank you also to the partner agencies
here today for such effective collaboration. With that, I’ll turn the floor over
to Deputy Attorney General Monaco. Deputy Attorney General Monaco: Thank
you, Madame Secretary and good afternoon. Today is a watershed moment. The Department of
Justice and its partners are holding accountable the world’s largest cryptocurrency exchange and
the CEO who ran it, for their criminal conduct. Binance vaulted to the top of the crypto market
in part through the scheme exposed today: by pursuing growth, market share, and profits
at the expense of compliance with U.S. law. Today’s charges and guilty pleas
– combined with a more than $4 billion financial penalty – demonstrate the
Justice Department’s commitment to corporate accountability. And they send an unmistakable
message to crypto and defi companies: if you serve U.S. customers, you must obey U.S. law.
A corporate strategy that puts profits over compliance isn’t a path to riches.
It’s a path to federal prosecution. As detailed in the statement of facts, Changpeng
Zhao was warned by his own compliance team that Binance lacked basic safeguards to
prevent users from evading U.S. sanctions. He was warned of the high risk associated with
some customers on their exchange. He was even warned that the CFO of another company had
been arrested for sanctions violations and that the same thing could happen at Binance.
But rather than implement the basic anti-money laundering safeguards that his team recommended
– safeguards required by U.S. law – Binance and its founder operated as though the rules didn’t
apply, as though they were beyond our reach. Crypto assets may be advertised as borderless
in nature, but the Department of Justice will enforce U.S. law across and throughout crypto
markets, even in their darkest corners. Some say the key to success in the tech sector
is to “move fast and break things.” Today’s actions show that if what you break is
the law, there will be consequences. Over five years, while building its business
with U.S. customers, Binance enabled nearly $1 billion in illegal payments involving
sanctioned countries and individuals. These actions put our collective security at risk.
Today, companies are increasingly operating on the front lines of the geopolitical
and national security challenges that mark today’s global environment.
That’s why the Justice Department is focused on the intersection of corporate
crime and national security. Today, corporate crime undermines not only our markets
and investors but also our national security. The laws we are enforcing today were
designed to protect the security of our financial markets—and to protect our financial
institutions from exploitation by terrorists and money launderers. Today’s actions show
that those rules apply equally to traditional financial institutions and those powered by
decentralized and cutting-edge technologies. Today’s resolutions are the result of, and a
credit to, the combined energy and expertise of prosecutors and law enforcement agents
from across the government. In particular, I’d like to thank Nicole Argentieri, the
Acting Assistant Attorney General for the Criminal Division; Matt Olsen, the Assistant
Attorney General for National Security; and Tessa Gorman, the U.S. Attorney
for the Western District of Washington. They each lead teams who have
worked tirelessly on this case. The partnership between the Criminal Division’s
Money Laundering and Asset Recovery experts and the National Security Division’s Export Control
and Counterintelligence experts is a response to the growing convergence of white-collar
and national security investigations, so we’re combining our deep expertise
from across the Department to combat these new and evolving threats.
Together with our partners, the Justice Department will hold accountable those
who occupy the C-suite and the boardroom if they exploit technologies in violation of our laws.
With that, I’ll turn it over to Chairman Behnam. CFTC Chairman Behnam: Good afternoon. Thank you,
Attorney General Garland, Treasury Secretary Yellen, Deputy Attorney General Monaco, and
all of our law enforcement counterparts. Today, the CFTC stands with the Department
of Justice and the Treasury Department in protecting U.S. investors and financial
markets from those who sought to create an empire through a calculated strategy
of regulatory avoidance and arbitrage, outright defiance of the law, and breaching
the fundamental principles of market behavior. Today, the CFTC agreed to resolve charges against
Binance, its founder and CEO, Changpeng Zhao, and its former chief compliance officer Samuel
Lim. Binance is the world’s largest digital asset exchange and offers trading in spot digital
assets and digital asset derivatives, including CFTC jurisdictional products such as bitcoin
futures, options, and swaps. The proposed orders impose a civil monetary penalty and disgorgement
totaling $2.7 billion against Binance, a $150 million civil monetary penalty against Zhao
and a $1.5 million penalty against Lim. Binance’s activities undermined the foundation of
safe and sound financial markets by intentionally avoiding basic, fundamental obligations that
apply to exchanges, all the while collecting approximately $1.35 billion in trading fees from
U.S. customers. Beyond the risks imposed on the U.S. financial system, Binance’s activities
impacted populations beyond investors in ways that cannot be measured in dollars and cents: as
evidenced by the internal chats of Binance’s CCO and others, Binance recognized that its platform
was used to facilitate criminal activity, including terrorist financing, but chose to turn
a blind eye, all in the name of profits. More disturbing, Binance and its leaders sought to dupe
and indoctrinate their employees and customers, building a cult-like following premised on
circumventing their own compliance controls to maximize corporate profits above all else.
As charged in the CFTC complaint filed in March of this year, and set forth in the consent order,
Binance made deliberate, strategic and calculated decisions to evade federal law over a period
of nearly four years. Binance, under Zhao’s direction and control, knowingly solicited and
accepted orders from US-based customers to trade digital asset commodity derivatives products and
operated an exchange for the trading of futures, options, swaps, and leveraged retail commodity
transactions. Throughout this time period, Binance never registered with the
CFTC, as is required under U.S. law. The resolution of the action against
Binance and Zhao—within just 8 months of its filing--solidifies the CFTC’s reputation
as the proven leader in the civil enforcement space when it comes to digital assets. We are
stalwart in ensuring CFTC registrants comply with our statute and regulations, which serve
to protect broader financial health and that directly impacts millions of American investors.
Binance failed to diligently supervise its derivatives market activities and miscarried
requirements to implement adequate Anti-Money Laundering, Know-Your-Customer, and Customer
Identification programs required for certain CFTC registrants. These provisions serve to
protect all Americans from those who seek to use the financial markets to facilitate criminal
activities including domestic and international terrorism. As there remain certain classes of
registrants who have lesser requirements, I believe our action here underscores what we could
accomplish in CFTC markets with broader authority. American investors, small and large, have
demonstrated eagerness to incorporate digital asset products into their portfolios. It is our
duty to ensure that when they do so, the full protections afforded by our regulatory oversight
are in place, and that illegal and illicit conduct is swiftly addressed. When, as here, an entity
goes even further, deliberately avoiding to employ meaningful access controls, intentionally
avoiding knowing customers’ identities, and actively concealing the presence of U.S.
customers on its platforms, there is no question that the CFTC will strike hard and aggressively.
I want to commend the incredible work of Candy Haan, Joseph Platt, Katherine Paulson, Joseph
Patrick, Matthew Edelstein, Elizabeth Pendleton, Scott Williamson, and Robert Howell. I would also
like to acknowledge our Director of Enforcement Ian McGinley and Principal Deputy Director
and Chief Counsel Gretchen Lowe. Thank you. Evan Perez, CNN: So one on topic and one
off topic question if you will indulge. Attorney General Garland:
That depends on the question. Evan Perez, CNN: So on the on topic, based
on the allegation of this and some of the other cases that you've brought I'm wondering
whether you know the concern in the industry about the ability of some of these startup
companies some of the smaller companies to abide by this very costly regulatory and
legal regimen that the United States requires whether it will mean that you can't really
do virtual currency and have this industry thrive and some of the cutting edge things
that Lisa Monaco just mentioned with that very heavy burden of regulatory compliance.
I'm wondering whether you have a message for the industry when it comes to that. And then if
I can ask my off topic question we're expecting at any moment the Israeli government and some
of the other parties to announce an agreement for the release of hostages in being held by
Hamas if you can comment on that and also just what the Justice Department and some of the
other agencies that are representative here are doing to respond to the attacks in Israel on
October 7th. We know obviously the Hamas has had a presence here in the United States and they're
concerned about how they raise money including of course by cryptocurrency is something that
is on everyone's mind. I wondering what you're doing about that in light of what happened.
Attorney General Garland: All right let me start with the off topic. I was in a meeting
this morning with National Security officials, law enforcement officials, and the president
regarding fentanyl and he told the press that his team has been actively negotiating over
possibility of bringing home some of the hostages they thought that we were very close
to being able to do that but that he couldn't say anything more at that time and I also can't
say anything more at that time at this time. With respect to the deaths of Americans we always
investigate deaths of Americans and we are actively investigating the deaths of the Americans
using all the tools available to us. We have as I think as the FBI director said at a recent all
threats hearing before the Judiciary and as I've said we are investigating Hamas connections in
the United States with respect particularly with respect to Financial support and that includes
cryptocurrency but we are also concerned about the possibility of more kinetic problems that
they could cause and we're investigating that. Now on the now I've talked a lot so on the
on topic question I will say you follow the law. You don't get a special benefit because you
think that you're what you're doing is better for society or better for small business or better
for big business or better for international. United States has laws and everybody including
cryptocurrency platforms have to follow the law. Chris Strohm, Bloomberg: There's been
a lot of concern about how unregulated the cryptocurrency markets are. You
were able to get these guilty pleas, it took a long time. I'm just wondering what
what do you how do you feel like realistically the significance of these guilty pleas are
what what do you believe it could what kind of impact could it actually have on the on the
cryptocurrency markets and then just a quick follow up is you know there is criticism that
this is not this isn't significant enough that there nobody there might be a situation which
nobody goes to jail and the penalty itself uh binance is able to pay that penalty um
how do you respond to that criticism. Attorney General Garland: I think I'm going
to call on on Nicole Argentieri who is the acting Assistant Attorney General for
the Criminal Division to answer most of the questions that you’re talking
about. The broader ones that have to do with regulation it's possible Secretary
Yellen or the CFTC Chair would address. Acting Assistant Attorney General Argentieri:
So I'll take the second question first. I think looking at the pleas today by every possible
measure these are some of the most significant penalties that the Department has ever imposed
on a financial institution. Not only is it one of the largest penalties imposed against a
financial institution this is the largest penalty that's ever been imposed on a money services
business. It's the first corporate resolution with a cryptocurrency exchange and it's the first
resolution with an MSB for sanctions violations. And the financial penalty is just it's not the
only significant part of the resolution. Binance which is the parent holding company is agreeing
to plead guilty and as part of that we're going to impose a monitor for three years. The company has
to enhance its compliance program and to continue to cooperate with the Department, so we think it's
quite a significant resolution. In addition the agreement with the company requires Zhao to step
down from his role of CEO and prohibits him from any present or future involvement in operating
or managing Binance. So we think this is a very significant resolution. In what tools do we have
and what should people take away from today I think that today's action show that if you serve
U.S. customers you must comply with U.S. law. U.S. financial institutions are the gatekeepers for
the safety and security of our financial system and because Binance served a substantial amount of
U.S. customers it was U.S. financial institution that was required to comply with anti-money
laundering laws and what those laws say is that Binance had to have an effective anti-money
laundering compliance program including procedures to know its customers and a monitor for suspicious
activity. And what happened instead is Binance and Zhao prioritized profit over compliance and that
failure to implement effective AML procedures led Binance to cause us customers to transact with
customers in Iran that violated U.S. sanctions. Treasury Secretary Yellen: Well just very
briefly I agree with the comments that were just made. We actually have rather strong legal
authorities to police this type of activity. Virtual currency exchanges are financial
institutions. Financial institutions of all sizes are required to comply with AML CFT
and sanctions obligations that they have and cryptocurrency or virtual currency exchanges
have those obligations as well. And I think today's actions show that we're very serious
about enforcing the strong regulations that are already in in place to make sure that
illegal transactions are not fostered by cryptocurrency entities. This is a regime
just as Banks can flourish meeting these obligations this is a regime that can support
responsible innovation. It's not meant to end cryptocurrency activities but to the extent
they occur it must be consistent with U.S. law. CFTC Chairman Behnam: I'll just say from
a market's perspective and distinguishing Secretary Yellen's comments about AML and KYC
I've seen and we've seen gaps in the current regulatory structure around digital assets.
I've advocated for filling in some of these gaps specifically around commodity tokens and I
do think if we're able to do that obviously with congress's help we can prevent these actions
from happening and not have to be here after the fact. Some of the traditional tools of
registration, surveillance, examinations, they've worked well for decades in the U.S.
financial system for both market regulators and we think those types of tools around
digital assets if improved and expanded would certainly help in preventing some of these
bad actions from happening again in the future. Stefania Palma, Financial Times: Hello. I had
a question both for the the DOJ and Treasury. So when it comes to the types of priorities
enforcement priorities in crypto that the DOJ has had there was a big focus obviously on
digital platforms that commit crimes or that at least let them happen. We've obviously seen the
DOJ bring big cases now against Binance, FTX, Treasury separately has also taken increasingly
taken actions against crypto players when it comes to money laundering or sanctions violations. So in
light of these actions having taken these actions in the market so far what are your priorities now
both for the DOJ and Treasury going forward when it comes to crypto oversight are you thinking of
deploying different types of strategies especially since we're seeing a growing aspect and angle
when it comes to National Security concerns beyond say a financial stability concern
when it comes to these crypto platforms. Attorney General Garland: Great question I'm
going to let the Deputy begin the answer for the Justice Department and kick it over
to Matt if needed on National Security Deputy Attorney General Monaco: Thanks very much
for the question Stefania. I mean first thing I'd say is these are incredibly complicated and
resource intensive and time consuming cases and so we need the resources and we're willing to
and have as we've shown today and in prior cases deploy those resources so we're always looking
to add our resources and agent investigators prosecutors. Second thing I'd say is you have
seen both of our actions today and in prior cases that we will be relentless in using every
tool that we currently have to deploy against those who seek to use technologies in a way
that abuse those platforms that cause the or don't prevent the use of those platforms for
illicit activities but we always want to make sure that we're working with Congress and others
to make sure those tools that we have today stay up to date. Right? We know that the bad guys and
the threat actors will try to exploit every crack and crevice they can to exploit technologies to
exploit gaps in the law. You've heard the CFTC Chairman talk about some of the tools he needs.
So we want to make sure the existing laws stay up to date and then I think we very much want to
work with those in Congress and others who want to ensure that we can deploy every tool possible
to make sure that the technologies that can help our prosperity and help our financial system
also aren't ripe for abuse by illicit actors. That's why you've seen us do things like create
the National Cryptocurrency Enforcement Team. That's why and Matt Olsson can speak to this
that's why they created the National Security Cyber Unit because what we're seeing is more
and more convergence of the exploitation both of the financial system and corporate crime in
the National Security space. I think I'll ask Matt to come up and I'm sure Treasury Secretary
Yellen might want to speak to this as well. Assistant Attorney General Olsen: Thank you
Lisa. I would just say briefly that as we respond to the nature of the threats we see
today around the world whether we're talking about terrorism we're talking about nation state
adversaries like Russia and and China and Iran we are increasingly using our tools sanctions
enforcement export control enforcement cyber security from nation state adversaries we're
increasingly seeing uh the ability to use the tools that we have in the Justice Department
from a law enforcement perspective to better protect the country by going after those threats
using those tools in new and innovative ways. So to your question we are constantly adjusting
our approach and our priorities to meet that threat on a daily basis and I think this
case is just one more example of that. Treasury Secretary Yellen: Well I would just
add that I think what the case today shows is that Treasury's priority is to vigorously pursue
investigations that involve sanctions violations or violations of AML CFT obligations that put our
nation at risk that degrade the global financial system that aid illicit activity and terrorism
and particularly in cases like this where there are violations of a truly egregious nature. So
as I've said well of course we want to make sure that our tools stay up to date and are adjusted so
that we can address emerging threats we believe we have strong tools and we've been increasingly
deploying them to counter this type of abuse.
