Press Release / / 02.04.22

Today: Int’l Groups Laud US Treasury on Rule to Counter Anonymous Shell Companies

23 International Groups Applaud US Treasury for New Rule to Counter Anonymous Shell Companies

Strict Enforcement, Closing Loopholes Urged to Strengthen Beneficial Ownership Transparency and Combat Illicit Finance

February 4, 2022 (Washington, DC) – Today, The Sentry led an effort among 23 international human rights and transparency organizations in submitting a letter applauding the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN)’s newly proposed rule implementing the beneficial ownership registration elements of the Corporate Transparency Act. The signatories also called on FinCEN to establish strong measures in the rule to eliminate loopholes.

Justyna Gudzowska, Director of Illicit Finance Policy at The Sentry, said: “The Treasury Department has a historic opportunity to enact a strong rule that will protect the US economy for decades to come by eliminating the favorite tool of human rights abusers and kleptocrats – anonymous shell companies. A robust rule without loopholes will go a long way towards curbing the appeal of the United States as a top jurisdiction for illicit actors to stash their ill-gotten wealth.”

Brad Brooks-Rubin, Senior Advisor at The Sentry, said: “Beneficial ownership registries can sound like arcane and mundane technical instruments. But the organizations signing this comment letter seek to remind the Treasury Department and broader public that, when implemented properly, they are an essential component of the integrated fight against corruption and human rights abuse. Our comment letter asks the Treasury Department to acknowledge the connection to human rights explicitly in the final rule and to ensure that, in the face of industry lobbying, the final rule remains strong.”

Representing a wide range of work on human rights and transparency issues around the world, from sub-Saharan Africa to China to Myanmar, the signatory organizations put a spotlight on the importance of strong beneficial ownership registration requirements in supporting accountability for human rights violators.

In the letter, the signatory organizations encouraged FinCEN to avoid any backtracking or weakening of the proposal that would allow human rights violators to have more opportunity to hide their financial interests.

Along with The Sentry, signatories were:

  • ADISI-Cameroun
  • Campaign for a New Myanmar
  • Clooney Foundation for Justice
  • Collectif SASSOUFIT
  • Democracy for the Arab World Now (DAWN)
  • EarthRights International
  • EG Justice
  • Friends of Angola
  • Human Rights First
  • Human Rights Watch
  • Humanity United
  • International Campaign for the Rohingya
  • International Corporate Accountability Roundtable (ICAR)
  • Jewish World Watch
  • Never Again Coalition
  • No Business With Genocide
  • the Opening Central Africa Coalition
  • Oxfam America
  • Public Interest Law Center (Chad)
  • Transparency & Accountability Initiative
  • Uyghur American Association
  • Uyghur Human Rights Project


Read the full letter:

For media inquiries or interview requests, please contact: Greg Hittelman, Director of Communications,

About The Sentry

The Sentry is an investigative and policy organization that seeks to disable multinational predatory networks that benefit from violent conflict, repression, and kleptocracy.

Pull back the curtain on wars, mass atrocities, and other human rights abuses, and you’ll find grand corruption and unchecked greed. These tragedies persist because the perpetrators rarely face meaningful consequences. The Sentry aims to alter the warped incentive structures that continually undermine peace and good governance. Our investigations follow the money as it is laundered from war zones to financial centers around the world. We provide evidence and strategies for governments, banks, and law enforcement to hold the perpetrators and enablers of violence and corruption to account. These efforts provide new leverage for human rights, peace, and anti-corruption efforts.

Co-founded by George Clooney and John Prendergast, The Sentry is a strategic partner of the Clooney Foundation for Justice. Learn more at