Project 2025 Tracker / What’s done, what’s next

22. Department of the Treasury · Minor · Needs Congress

Require FinCEN and GAO evaluations of the AML-CFT regime's effectiveness

Not started

707 22. Department of the Treasury

“Congress should also require both FinCEN and the Government Accountability Office to undertake separate evaluations regarding which aspects of the AML-CFT regime are effective and which are not.”

What has happened

  1. Not started

    Congress has still required neither evaluation, and that is the ask: no enacted law and no one-chamber-passed bill directs FinCEN or the Government Accountability Office to evaluate which aspects of the AML-CFT regime are effective and which are not. Both bodies did nonetheless produce work in the window, and neither piece is the evaluation the Quote describes. **GAO** published GAO-26-107967, *Corporate Transparency: Treasury Should Address Gaps in Ownership Information Resulting from Expanded Exemptions*, on 2026-05-29 — a real effectiveness finding, but about one rule rather than the regime: FinCEN's March 2025 interim final rule exempting domestic companies and U.S. persons from beneficial-ownership reporting "applies to over 99 percent of entities that previously were required to report", and GAO warns that because "Treasury's 2026 National Money Laundering Risk Assessment identified several cases in which shell companies were used to facilitate financial crimes", the exemption "may perpetuate these risks". **FinCEN's** own in-window instrument is the compliance-cost survey at #1988, which measures what the regime costs and not what it achieves. Under §3b's Requires-Congress ladder neither is executive action *on this ask* that would reach `attempted`; they are the record moving nearby.

Research log

What was searched, and what didn’t count as evidence

Research notes

Cluster negative search shared with #1988 and #1990, recorded in docs/research/ch-22.md.

Adjacent and not counted: the Anti-Money Laundering Act of 2020 already requires some FinCEN reporting to Congress; the Quote asks for something further, and nothing further was enacted.

Read-queue ticket 07, 2026-09-06. The GAO half of this ask was searched by the settled route — paging gao.gov/agencies rather than guessing a product slug — and it has a limit worth recording. There is no FinCEN agency page on GAO’s site; the relevant one is gao.gov/agencies/department-treasury, and that page is an open-recommendations view rather than a full product list. Its ?page=2, ?page=3 and ?page=4 return byte-identical bodies to page 1, so it ends where it appears to. GAO’s own catalog could not be searched by subject: gao.gov/topics is category-level only, and gao.gov/rss/reports.xml, gao.gov/rss/all.xml, gao.gov/sitemap and gao.gov/sitemap.xml all fail scripts/fetch-page.mjs’s content check. So “GAO-26-107967 is the only in-window GAO product on AML/CFT effectiveness” is not established; what is established is that it is the only one the agency page yields. Per §3b, a negative search must say how far it reaches, and this one reaches the Treasury agency page and no further.

Two leads for a later pass, both surfaced by that report and neither opened here: Treasury’s 2026 National Money Laundering Risk Assessment, which GAO cites and whose Treasury URL was not found; and Treasury press release sb0603 of 2026-08-11, FinCEN Permanently Ends Beneficial Ownership Reporting Requirements for Millions of Small Business Owners, published ten weeks after GAO’s report and moving against its recommendation. Both belong to #1991 and #1992 rather than to this item.

Action
other
Object
evaluations of the AML-CFT regime
ID
1989