Yesterday, Treasury’s Financial Crimes Enforcement Network (FINCEN) released this advisory to banks around the world to be on the lookout for deceptive financial practices designed to move the ill-gotten wealth of 18 former Ukrainian officials, including Viktor Yanukovich. The chilling effect of this will likely be that banks around the world refuse to move large sums of money for mysterious figures linked to these 18 people, for fear of losing their access to the financial system. Although the advisory says “U.S. financial institutions,” in financial regulation, that term is understood to mean any financial institution when it’s accessing the U.S. financial system. As a practical matter, that’s just about every bank on earth, especially when you consider that around 80% of international transactions are denominated in dollars.
Nothing about that troubles me. You’ve probably seen the pictures of Yanukovich’s palace by now and made the sensible inference that he didn’t pay for that on a civil servant’s salary. That wealth is likely derived from kleptocracy, something Treasury has gotten increasingly good at blocking as it moves through the financial system. So nothing here should be read as a dig against Treasury. It’s only doing what the political leadership is telling it to do.
Yet, weeks after the U.N. Commission of Inquiry issued a report that makes North Korea’s crimes against humanity pretty much undeniable — and months after even I knew that the Commission would say as much — the Obama Administration has done exactly nothing about it. It hasn’t even committed itself to push for a vote in the U.N. Security Council.
Let’s unpack what that tells us about the priorities of the Obama Administration. Kleptrocracy that hasn’t resulted in mass starvation is now a higher enforcement priority than kleptrocracy that may have killed 2.5 million people, and that perpetuates one of the world’s top threats to both the global financial system and the global counter-proliferation system. Massive non-lethal corruption is a top priority. Crimes against humanity — including murder, rape, extermination, mass starvation, racially motivated infanticide, and the operation of gulags — are not a priority for the Obama Administration, period.
Either (1) John Kerry really thinks he’s this close to Agreed Framework III, (2) we’ve outsourced our North Korea policy to our friends in Beijing, or (3) nobody gives a damn.