 everyone to global financial integrity's launch event for Frank Vogel's new book, The Enablers, how the West supports kleptocrats and corruption endangering our democracy. I'm Tom Cardamone, president and CEO of GFI. And for the next hour or so, we'll dive into many aspects of an issue, corruption, that has really come to the fore given the numerous and constant scandals that got a lot of media attention. And also given that President Biden has made fighting corruption a key pillar of his administration. The enablers comes at a time of increasing focus on lawyers, audit firms, real estate industry, private equity, and the art market, among others, and how they're able to aid in a bet, money laundering, corruption, and kleptocracy. Frank's book covers many sectors, including banking and global trade, as well as our faltering regulatory system. And he notes how these adversely impact democracy. After Frank's presentation, we'll have three discussions and possibly, depending on time, a few questions from the audience. Since we have just an hour today at the outset, I'll provide brief bios for our very knowledgeable panelists and then call on each of them in turn to provide their comments. I wanna first introduce Raymond Baker. Raymond is an international entrepreneur, turned scholar, turned think tank founder. He began his career in the early 1960s, purchasing and running companies in Nigeria after having received his business degree from Harvard. After returning to the U.S. in the mid-70s, he continued his global business dealings until he retired. And while at the Brookings Institute, began conducting research into corporate manipulation of global trade for what would become a book titled Capitalism's Achilles' Heel, Dirty Money and How to Renew the Free Market System, which was published in 2005. The following year, he found a global financial integrity to research these issues further and now he continues to serve as treasurer on the GFI Board of Directors. Welcome to Raymond. Our second discussant is Zoe Ryder. Zoe's Director of Civic Engagement for the Project and Government Oversight where she leads an effort to engage stakeholders in communities affected by corruption and abusive power to push for more accountable and ethical federal government. Prior to joining Pogo, she was with Transparency International for more than 10 years, which included working with anti-corruption activists and reformers from around the world to ensure strong public accountability. Zoe is also co-founder of the Anti-Corruption Data Collective, which convenes journalists, data analysts, academics, and policy advocates to expose transnational corruption and push for policy change. Great to have you with us, Zoe. And third is Alex Gillies. Alex holds a PhD in International Relations from the University of Cambridge where she researched the political economy of the Nigerian oil sector and she spent her Fulbright year in 2008 working in Nigeria. She currently manages the anti-corruption program at the National Resource Governance Institute as an expert on oil sector corruption. Prior to her time at NRGI, Alex was a consultant for the World Bank, DFID, USAID, and several political risk firms. She is the author of the recently published book titled Crude Intentions, How Oil Sector Corruption Contaminates the World. Thanks, Alex, for being with us today. And our focal point for the next hour, Frank Vogel. Frank is a former senior World Bank official. Prior to that, he was a business and economics correspondent for the Times of London. He's the co-founder and former vice chair of Transparency International and is the author of several books on corruption and corporate scandals. He currently teaches a graduate-level course at Georgetown University, titled Corruption, Conflict Resolution and Security. Frank, it's great to see you. Congratulations on the publication of the book. The floor is yours. Tom, friends, colleagues everywhere. Thank you so much for inviting me. Thank you for this event. Thank you for the wonderful work the GFI does and continues to do. Let me start by just framing this very bluntly. As tens of thousands of people were being murdered and raped in Darfur in Sudan. The then president of the country, Omar El-Bajir, who was wanted by the International Criminal Court for Crimes Against Humanity. At that very moment, he had other things on his mind. He was working with executives of BNP Paribas, a major French bank through their Geneva office in violating US sanctions and laundering $6 billion of stolen loot into investments in the United States. BNP Paribas just threw morality to the winds and also couldn't care less, it seems, about the law. The French government, when hearing that the Justice Department in the US wanted to find BNP Paribas, pleaded for low fines, saying that this could endanger the whole banking system. At the same time, after the fines were paid and after BNP, of course, carried on paying its dividends to its shareholders, the top officials of BNP were never prosecuted. There was no punishment at all. The fines, it seemed, were just like another cost of doing business. And what's happened at BNP Paribas, and I tell the story in my book, has happened in one bank after another and one government after another has come and said, you know, don't punish these banks too much. And that's part of the complicity. So I want to today thank Tom, Zoe, Alex for participating in this discussion of what I think is both a very important economic and financial story, but more importantly, a political story. I've been trying to follow the money for years. My roots once took me, oh, many years ago, to the office in the Brookings Institution of Raymond Baker. And Raymond was just finalizing his wonderful book that Tom has mentioned. It's called Capitalism's Oculus Heal. So here you are, I'm showing you his book, not my book, because it was absolutely a pioneering work, not just for the detail, not just for explaining illicit finance, but most importantly, by showing how this illicit finance, how this criminality affects and undermines free markets, undermines trade, leads to lawlessness, leads to inequality, encourages poverty. These are the big themes. And I learned at first from Raymond about them. And then sometime later, thanks to Raymond again, he hosted an event where I had the opportunity to meet Robert Morgenthau, the legendary Manhattan Attorney General, who fearlessly went after the biggest banks and the people who sort of tried to give respectability to those banks, including some very, very prominent lawyers, such as Clark Clifford. Morgenthau just tirelessly went after them. He prosecuted them. He showed tremendous courage, but he could do it in part because he also had substantial resources to go after them. One of the main themes in my book is, we are undermining our prosecutors and our enforcement. We're not putting the resources into prosecuting the crimes that banks like BNP Paribas or Deutsche Bank or HSBC or JP Morgan Chase or Goldman Sachs, I could go on, have all committed in the realm of money laundering and corruption. I start my book with a quote from President Biden, who last summer said, and I'll quote, fighting corruption is not just good governance, it is self-defense. It is patriotism and it is essential to the preservation of our democracy and our future. And the reason why I start with that is to emphasize that my book fundamentally is a political book because we see authoritarianism rising in the world, we see democracies troubled, we see some authoritarian regimes directly trying to undermine our democracy and all authoritarian regimes are run by kleptocrats who steal from their people. And moreover, and I hope this is clear from the book, they use the world's financial system to hide their wealth and strengthen their power. And so the book is called The Enablers because it's about the banks, the lawyers, the auditors, the real estate and yacht brokers, the art dealers, the financial consultants who in one way or another, based in Wall Street, based in the city of London, based in other financial centers, aid and the bet, the kleptocrats to move their money into Western investments and then hide those investments. The scale of this criminality is vast. GFI alone has put the figure of over a trillion dollars of just trade-related money laundry. When you look at the Transparency International Index, you find that over 120 countries are perceived to be corrupt or governments rather corrupt or highly corrupt. We are talking about a universe of corruption. Unfortunately, one where the democratic governments themselves are complicit and where they're leading financial institutions are key players in this criminality. The book covers 14 chapters. I'm not gonna go into any of them in detail. I just wanna say the first three chapters set the scene. The fourth chapter goes into the banks themselves to explain the criminal actions that they are doing and how they get away with them. And to make the point that the pressures on banks to be competitive from many sources has created a situation where they are not risk averse. They're taking very high risks. And when they're fine, they just brush it off as the cost of doing business, no more than that. That high risk environment created the subprime mortgage crisis and it has created an enormous amount of money laundering activity by the banks but also by the other enablers. I go into the bond markets, which are legal but which provide huge amounts of money to the authoritarian kleptocratic governments. Just give you one example. Western investors, again with bond issues managed by Western financial institutions have raised over a hundred billion of bonds and notes for Gazprom. Gazprom is the state natural gas enterprise of Russia that Putin is using today to exert enormous pressure, political pressure on Western Europe. Gazprom operates because we're providing it with the money. We need to think about that. And all that that implies to ask, why are we doing this? Well, part of the reason is because we haven't had the sufficient political focus on all of the issues in this book and so much of the work that GFI does and so much of the work that my colleagues here on this panel do. And part of that comes to again to complicity but also to what I call the slumbering regulators. At times they seem asleep. How could it possibly be? Just ask yourselves, how could it be that $235 billion of dirty money loot flowing from Russia and Belarus and Azerbaijan could go through the tiny branch of Danzko Bank in Estonia, a country that's tiny and has back regulators of course. For year after year, huge amounts went through that bank. Nobody discovered it in the official community. It only came to light because of a whistleblower. I could give you many other cases that affect major banking institutions, Goldman Sachs, Credit Swiss. In their cases, they laundered money that deprived the poorest people of Malaysia and Mozambique, for example, of vitally needed development funds. They are victims, real victims of all of these crimes. I deal to some degree in the book with other enablers of course, with the real estate brokers who've created what has now become London Grad. From Ontario and Vancouver to Miami, we see an enormous amount of dirty money going into real estate. And one of its consequences is pushing up the prices for ordinary citizens of buying a home, of buying an apartment. So it has real consequences in those terms as well. I go into many, many aspects of enabling, yes, the front man. But, you know, all of this is well and good. I go into the natural resources area and to the arms area because here, Western governments have been so keen to sell arms or to do dirty deals and extractives with authoritarian, kleptocratic governments that they seem to have put aside the rhetoric against human rights. And every time we see major corruption in highly authoritarian countries, we see human rights abuses. So where does this all lead us? The book, having mapped out the territory of criminality of the enablers, comes to the three final chapters about reform. I start with trying to reform the culture of banks. I try and make an argument that banks must start to look again as they did for many, many years at serving the public interest and not just the short-term profit maximization. And there are many bankers. I'm glad to say who support that. And, you know, when Goldman Sachs after it paid all its fines for its Malaysia dealings actually issued an apology, then that's a good start. And Zoe asked me before this panel if I could give some good news. Well, at least Goldman Sachs apologized, but I'm not sure that's sufficient. And that's why I also call for major administrative reforms. I'd like to see know-your-customer rules, which mean that all of the enablers, the real estate brokers, the art dealers, the banks that they all have to demonstrate they know where the money comes from for the clients they serve. There has to be much greater due diligence. And these know-your-customer rules have to be enforced, strictly enforced. We need to give the resources to the banking regulators, to the justice departments, to the FBI on both sides of the Atlantic to really enforce these rules. We have to get rid of the offshore companies and the trusts and the show organizations that mask who the true owners are of the real estate and all the other assets. And also I suggest we need new laws that make the top executives of these institutions do the enabling criminally liable in the event that their institutions are in fact court red-handed. These people dare not get away with it in the way they are today. And finally, just to end, I try to make a political point. I argue that money in politics is absolutely at the core of so much of what is happening. The bankers and the enablers, top lawyers and others, are so plugged in to the political elites on both sides of the Atlantic and they use those networks to influence political decisions. In the US, they give huge campaign contributions. At the same time, they have armies of lobbyists. And all of this is to guard against tight enforcement of the rules, to ensure an open, basically poorly regulated market that allows them to aid and abet the kleptocrats. We need to stop that. You will say, I'm sorry, I'm unrealistic. Fortunately, there are people across the world who are fed up with the corruption. They are protesting. The opinion polls show people in this country and elsewhere no longer have much trust in government and partly it's corruption. And at the same time, we are wonderfully courageous people, a younger generation like Zoe, like Alex, who are going to march forward and are doing much more innovative things in order to ensure that we really do speak truth to power starting with the enablers. So Tom, thank you so much for this opportunity and thank you everybody who's interested in my book, The Enablers. Thank you. Thank you very much, Frank. What a great overview. And I think the key, if you're to pull one key theme out, it is the political connection to all these other problematic issues in the money and politics and Citizens United and so on and so forth. So no doubt this is going to bring forth a lot of questions from the audience. But before we get to those, let's go to our three discussants and first off will be Raymond Baker. Raymond. Can you hear me now? Yes, we can. Okay, give me a second. My laptop has only... Raymond, should we go to the next presenter or are you having difficulties? I'm having difficulty, but I'm trying to get on. All right. Well, why don't we go to Zoe and then that'll give you five or 10 minutes to get your laptop where you need it and then we can circle back, how's that? That's fine. Okay, very good. Zoe, let's go to you. Thanks, Tom, I really wanna thank you for the opportunity and the honor really to be a discussant on this panel with such tremendous group of people and it's such an important book. And first, I really wanna commend Frank for his book. And I'm not sure he said it today, but I have heard him speak about the intention behind this book, which is to increase public understanding of the activities of the enablers and why they're so damaging. And someone who has worked as a regional and global program manager for Transparency International, focusing on international corruption issues and now focusing on US corruption issues. I think that goal is really critical and not easy. And so I want to lay out some initial thoughts on what I think it'll take to get more Americans engaged on this issue. And so first and foremost, I would argue that we should move from a framing or expand, better said, from a framing of Western enablers of foreign kleptocrats to one of a transnational enabling system that is sustained by financial secrecy and that undermines the lives of people living in the US as well. The enablers opens with a quote from President Biden. And I quote, fighting corruption is not just good governance, it is self-defense, it is patriotism and it's essential to the preservation of our democracy and our future. Unquote. These words are taken from a June, 2021 published statement by the president introducing the national security study memorandum on the fight against corruption and was issued, I would argue, largely for an internationally facing audience. And despite these promising words by the president in very concrete ways, multiple institutions in the US from the White House to private and public donors to civil society ourselves are organized around certain framings of corruption that I think are limiting our potential impact and are unlikely to engage the public here in the US as adequately as we need to in order to tackle the problems of political will and increase the political persuasion for reform. So I'm gonna talk about what I see as too interrelated in limiting frames. First is the limiting frame of domestic good government versus foreign corruption. One of the things that continues to strike me as I've moved from a focus on international corruption to US corruption is how institutionally civil society is largely divided around one or the other. This increasingly inadequate bifurcation is reflected, I would argue, if not directed by donors who themselves tend to divvy up along two disconnected spheres, good government at home, corruption and kleptocracy abroad. There are far too few donors finding, funding the likes of the few leading US based civil society protagonists such as global financial integrity, fact coalition who treat corruption for what it is, a transnational problem. This continues to astonish me given the fact that the major domestic corruption story of our time, President Trump's first impeachment was entirely a story of transnational corruption. The most recent example of how this divide is institutionally operationalized in the US is the organization of the Summit for Democracy which is to be held on December 9th which is International Anti-Corruption Day and December 10th. Here's what we've seen so far. The National Action Planning led by the Domestic Policy Council which is responsible for the domestic work around the three themes, authoritarianism, corruption, forgetting the third theme but it's just as important, has involved no civil society from the anti-corruption or pro democracy space. While on the other hand, the State Department and USAID are making every effort possible to involve internationally focused civil society the planning of the summit activities involving foreign countries. We have also seen the Biden administration say next to nothing about the most significant piece of it domestic anti-corruption pro-democracy legislation that protect our democracy act which tackles foreign influence in our elections among other things and addresses many of the potential abuses of power by the executive branch illuminated by the previous presidency. And if anything, a recent survey by the project on government oversight Pogo shows that if Biden has an anti-corruption message it is not hitting home. In our survey of likely voters in the battleground states of Ohio and Michigan published last month, corruption continues to be identified by more voters as a serious problem facing the country than any other issue that includes infrastructure, climate change, jobs for the pandemic. And they see the problem worsening over the past 10 years with little being done to change the status quo. And while America's steady decline of trust in our public institutions is well documented these very recent findings should be no less concerning. Just as concerning as according to recent international polling by Pew of other wealthy democracies around the world that loss of trust in US democratic institutions is shared globally. In other words the world is losing trust in our democracy. Which brings us to what I would argue was the limitations of frame two corollary of frame one that of Western enablers and foreign kleptocrats. This framing has been established for several years at least and narrates the very true story of kleptocrats laundering their assets in Western economies benefiting from both the rule of law and stability that govern those economies and the financial secrecy that it negros those economies especially in the US. The enablers are the professional class that facilitates that but in that framing we lose sight of who the real power brokers are in keeping us in financial darkness. While lobbyists for corrupt politicians from Guatemala to Russia have set up shop here in the US and certainly have had important successes it isn't their lobbyists who continue to keep private investment funds exempt from our anti-money laundering regime or the corporate transparency act. It is the $15 trillion industry itself. It isn't the lobbyists for kleptocrats who will try to keep trust exempt from the corporate transparency act but rather the undue influence of billionaires here working to protect some of their favorite mechanisms for major tax avoidance. The exemption of a favorite form of influence peddling from the corporate transparency act, nonprofits, yes certainly not thanks to lobbyists for kleptocrats. The robbing of the public purse whether through instruments of kleptocracy or through legal undue influence of the wealth hoarders to steal a phrase from Chuck Collins is facilitated by an enabling system that is transnational and wholly sustained by financial secrecy here in the US. But don't get me wrong, it is essential to tackle money laundering more robustly with greater public resources and public scrutiny which is why I co-founded together with Frederick Obermeyer and David Sikoni the anti-corruption data collective two years ago also known as ACDC. And one of the first sectors ACDC decided to look into is the private investment fund sector because as the leaked FBI report of 2020 will tell you it is increasingly a destination for money laundering. But the more we look under the hood the more forms of economic extraction we find that result from deft and creative influence peddling by the lobbying arm of that industry as exemplified by our report public money for private equity which showed how large private equity backed companies were taking billions in US taxpayer dollars meant for small businesses under the COVID relief program all perfectly legal. So my central point here is that dark money, dirty money and big money all collude to protect this enabling system. In other words, we want to actually be effective in the war against grand corruption here or abroad until we expand from a frame of bad Apple enablers for foreign kleptocrats and address how the undue influence of wealth hoarders here buttresses and protects an entire enabling system that is transnational and sustained in the US by our financial secrecy. The most powerful participants and the vast majority of participants in this web of opaque financial structures probably never laundered a cent in their lives. And that is the real challenge and until we can make a more visible connection between financial secrecy and economic injustice here at home across the political divide the enabling system will stay intact. Politically, this is the only way to put enough pressure on our elected officials to change the system from what anthropologist Jane Waddell calls structured unaccountability to one of accountable capitalism. Thank you. Sorry about that, thanks Zoe very much. Again, key point being the amount of money in the political system drives a lot of this activity and hides a lot of this activity. So we seem to be on the same page here. Thanks very much. Let's go to Raymond. Thank you, Tom and apologies for that computer glitch. And thank you Frank for your kind words, most appreciated. But we're gathered to say thank you to Frank, to you Frank for a lifetime of focus on corruption and transparency and integrity and now bringing it home to our own democracies. You've written a superb book that will have legs for a long time to come Frank. I wanna frame my remarks around a simple question and then try to answer that question in line with Frank's remarks and Frank's book. The question, how do you curtail the supply of something that is in endless supply? How do you do this? My favorite example of this is drugs coming into the United States. And my favorite organization to criticize is the Drug Enforcement Administration created by Richard Nixon in 1973. That's 48 years ago to wage an all out war on the drug ministers. Well, across these 48 years, DEA has never curtailed the supply of drugs nor increased the price of drugs coming into the United States. Minor blips along the way, but nothing substantial or sustained. How do you explain this failure? The answer is straightforward. DEA has been trying to curtail the supply of something that is in endless supply by their own admission. 90% of their agents address the supply problem and only 10% of their agents look at the money law. Okay, what else is in endless supply? Human beings available to be trafficked are in endless supply. Women and men for sexual exploitation are indentured labor. There's an unending stream of these poor souls. Animals are in endless supply. You may run out of elephant tusk and then you can turn your attention to pangolin scales, but there's virtually no limit to the supply of animals to be trafficked. Fish can be stolen in unlimited quantities in unbetrothed waters and then brought into our northern markets. Resources, particularly oil and minerals can be stolen. This has been going on for decades. Trees are in unending supply to be illegally harvested and then brought to other countries for lumber or furniture or paper or what have you. And then perhaps the biggest one of all, the flow of corrupt money, Frank, has focused on corruption for decades. And I think it's easy to say that the flow of corrupt money is virtually in unending supply. It's quite possible that the flow of corrupt money is at the highest levels ever. Let's take corruption through its advancing realities Years ago, we used to talk about corruption as being theft by a few officials. And then we elevated the concept to the idea of grand corruption. And that was massive amounts of money stolen and sent into foreign accounts. And then over the last decade or so, we have been talking about state capture, where the whole of the governing apparatus of a country pursues illicit enrichment. And then lately, we've been focusing on another level which is kleptocracy. This is not quite the same thing as state capture of the administrative apparatus. Instead, kleptocracy is a small group of people who effectively become the state, effectively above the structure of the state. Now, we've been fighting corruption for decades, kleptocracy for a few years. Yet as I have indicated, I think the flow of corrupt money may be at the highest levels ever. We've succeeded in reducing this phenomenon out of some countries, but we are now faced with literally hundreds of billions of dollars coming out of Russia and China. I think the actual cross-border flow of corrupt money is probably at the highest levels ever. So back to my question, how do you curtail the supply of something that is in endless supply? Drugs, people, animals, fish, trees, resources, now even the wealth of nations. I think we cannot succeed in this effort by continuing to focus on the supply because the things that I've mentioned and more are in endless supply. DEA and other failures make this clear. So if you cannot curtail the supply, how can you succeed in curtailing these realities? And the answer is to focus on the money. The criminal and the corrupt are in business to make money. The kleptocrat, Steve's theft as a means of maintaining power. There is no such thing that I know of as a kleptocrat who eventually has all he wants and says to his colleagues, you go ahead and steal how much you want. No, the continuation of theft is a necessary instrument of power. The kleptocrat has to continue to be the thief in chief to remain in power. So if we cannot curtail corruption by these means, what is the answer? That brings us to the enablers. We have in the Western countries created a financial secrecy system over the past half century that handles so much of the money that is taken by the corrupt and the criminal and now the kleptocrat. We have been the ones to create the tax havens, secrecy jurisdictions, disguised corporations, anonymous trust accounts, fake foundations, money laundering techniques that enable the corrupt and the criminal and the kleptocrat to harm their countries and our shared world. Not only that, we've also left holes in the laws of our Western countries that facilitate the movement of money through this financial secrecy system and ultimately into our own economies. Every single element of the modern financial secrecy system has been created by us in the Western countries, not a single element has been created by them over there. We are not experiencing something that has been done to us but something that has been done by us. Now, let me be complete. There are a couple of elements of the modern financial secrecy system that precede us. That's Hauwala and Chinese flying money. In my estimation, probably 99% or more of Hauwala transactions are small remittances going from family members in one part of the world to family members in another part of the world. Chinese flying money, I think, is more serious. Chinese companies are using their flying money mechanisms to move their profits and revenues from resource investments, from construction projects, from ports management activities and more. And recently, Chinese flying money operators have largely taken over the business of laundering money for Mexican drug cartels, also Central and South American cartels, drawing upon their experience of handling this money for Asian traffickers for years. Now, this idea of focusing on the money more than the supply, has this ever worked anywhere along the way? Yes, in the business of terrorist financing, this is a success story. After 9-11, the US government appointed 51 organs of the government to focus on terrorist financing. And with this extreme focus, we succeeded in pushing terrorist financing out of the legitimate financial system. European governments and other governments got angry with us because they thought we were heavy handed. Had I been in treasury at that time, believe me, I would have been heavy handed too. But it worked. We pushed terrorist financing out of the legitimate financial system. Terrorists are more focused locally these days, working to make money through theft and extortion and smuggling and so forth. But the cross border flow of corrupt money has been very substantially reduced. Needs to have continuous focus, continuous emphasis, but this is a success story. So let me summarize my remarks. I'm advocating that instead of focusing on the supply, which cannot succeed when you're dealing with something that is an endless supply, we instead refocus much more of our attention on the money, which means focusing on the enablers, which means focusing on ourselves. We cannot succeed focusing on the supply. We can succeed focusing on the money. Frank, your book focusing on the enablers makes a signal contribution toward rechanneling our efforts to focus on the money. Congratulations, Frank. Thank you, Raymond. Follow the money, which was the central lesson from the Watergate scandal, which was almost 50 years ago. Now it seems like the government, the country's forgotten the lesson. And it's a good one to remind us all of, because it's the key thing that I think we need to be focused on. It all took with some political will to address terrorist money in a financial system. If we can do it for that, I think we can probably do it for the other areas as well. Thanks, Raymond. With that, let's go to Alex. Great, thank you. Really appreciate GFI for having me here today and congratulations, Frank, for the publication of this very timely book. This is when we really need these kinds of calls to action if we're to have any hope of moving the needle on this challenge. And it's a real honor to be here because I've admired your work and your passion on these issues for a really long time. Given the time, I'm gonna quickly offer three points around how we might make progress on this front with a focus on the global dimensions, though really do wanna endorse everything that Zoe said, which I thought was really quite powerful. The first is, you know, Frank mentions a few of the reforms that we really urgently need, improvements in beneficial ownership transparency and spreading that to property markets and elsewhere, improvements in the anti-money laundering system, stronger due diligence requirements for these lawyers, accountants, and other service providers. But because of the intensely transnational nature of corruption, these kinds of reforms have to be global if they're going to work. The US or any other government can't act alone. And I think the summit of for democracy coming up in a few weeks, which Zoe mentioned could be, you know, a great vehicle with US leadership to take this agenda forward and get the kinds of global collaboration that are needed to do the work that we all know needs to happen. I think the case has been convincingly made here, but also it's pretty well known at this point that these steps are necessary if we want to reduce illicit financial flows. But this is only gonna happen with strong US leadership and it's unclear, whether that's going to unfold. And I think it would be a real missed opportunity if this agenda didn't feature very high up in the summit for democracy because it seems like a very timely way to move it forward. Second, a bit more broadly, a lot of the discussion around enablers of corruption focuses on how corrupt actors move their money offshore and how they spend it abroad on luxury property or private jets or whatever it might be. And then all of the actors that helped that happen, the jurisdictions where the shell companies are based, the banks, the real estate agents, et cetera. I do think we also need to look at how corrupt actors get the illicit money in the first place. How did the money escape their countries, not just what happens to it once it's already been captured? And this stage has plenty of foreign enablers as well. My work focuses on corruption in the oil gas and mining industry. And this is one sector where political elites go to get rich, where they go to get the money for their families or their allies or to buy off their enemies or whatever it might be. And often in these situations, you do see foreign entities, including mining companies and oil companies playing very helpful roles in that pursuit. And I can share a couple of kind of scenarios for what this looks like in practice where oil companies didn't engage in corruption directly but definitely helped individual corruption schemes to work or wider systems of kleptocracy to work. In Nigeria, under the previous government, a few local oil companies received large quantities of crude oil on very favorable terms because they had close ties to the oil minister at that time. These local companies then sold their oil to big international oil traders. These international oil traders didn't necessarily engage in corruption or anything that could be called criminal by buying that oil. But without them, the Nigerian companies would not have been able to cash in off this scheme. So it is kind of playing a classic enabling role. In elsewhere, in Angola, we've seen large companies for years partner with members of the Inner Circle of the Dos Santos regime in order to receive favorable business opportunities in that country. These kinds of enabling behaviors end up enriching political elites and trenching kleptocracy. And of course they happen outside the oil sector as well. They also need attention. We have to look at how enablers are helping corrupt money escape from the system, not just what happens to it after it's already escaped and in some cases is too late. The third and final point I want to make is there's one question that kind of cuts across all kinds of enablers and that's who's okay to work with and who isn't. And if they get this wrong, they often end up enabling corruption one way or the other. This is the question that lawyers, banks, accountants, real estate agents, not to mention oil companies and defense companies but even universities and charities have to ask and they have to get right. And some of the reforms and new kinds of regulation and law enforcement that are needed certainly will help but all kinds of firms are gonna still be faced with that judgment call. I've discussed this issue with a lot of compliance personnel from oil and mining companies. And I think it is genuinely difficult in some cases which Russian billionaire is okay to work with and which is not. Which Nigerian oil company is a credible domestic oil company and which one exists solely because they made corrupt deals with the right people? In contexts like the UAE or Qatar, which company owned by a royal family member is a credible business and which one creates an unacceptable conflict of interest? Frank, you mentioned Gazprom. On one hand, it's obviously an integral part of Putin's kleptocracy. On the other hand, it's the largest publicly listed gas company in the world. And so these are difficult judgment calls around, who's okay to work with and who isn't? A lot of them are much more black and white and people are getting it wrong even though they know much better. I'm not trying to say that but I do think as we push forward on this issue of enablers, shifting norms on this question of who's acceptable to work with has to be a part of the equation. Another really powerful illustration of this for me was the Luanda leaks which many of you would be familiar with which kind of revealed the business dealings of Isabel Dosentos, the daughter of the former Angolan dictator. And it revealed how all kinds of very credible Western companies were working with Isabel Dosentos including on deals that had a ton of red flags associated with them. Now it wasn't that they hadn't done their due diligence or that all these shell companies obscured her ownership in these companies. The consulting firms and everyone else knew full well who they were working with. They just decided it was a risk work taking that the norms and the kind of reputational impact of that business relationship said it looked fine. And it was only when the leaks came out and all the bad press came that they kind of went then went running in the other direction. So there's no simple answer here but I think there are improvements to be made and I think this is another aspect of this enablers question that needs to be on the table as we move forward. So above all, I really just wanna add my voice to everyone urging for policy makers and activists and everyone else to pay attention to this enablers question and to thank Frank for helping give it the attention it deserves, thanks. Thanks Alex, I appreciate those three points. I think perhaps the most important was your first one which is the need for leadership and political will. The US has certainly showed it in the context of the SCF CPA. It appears that the Biden administration is trying to do something similar within the context of the Summit for Democracy. So we'll see if we can get some multilateral agreements to attack this problem. We don't have a lot of time left but I think there's been several very good questions. I think we should put to at least to Frank in the first sentence and maybe have the other panelists jump in but Frank to your point about trying to get the banks to the point where they go back to how they used to see themselves as a sort of a good neighbor and their business was to help their customers. That seems like we're a long way from that. One of the questions asked if the ESG standards that are becoming very common now are likely to have any positive impact on the banks in that regard. Thank you, Tom. First of all, let me thank Alex and Zoe and Raymond for those fabulous comments and thank everybody for the terrific comments in the chat as well. On this question, global witness just last week issued a very important report, I think, on financing and the environmental climate change challenge and it is a call basically to look far more seriously at what financial institutions are doing in the whole area of climate change. We dare not allow ESG just to become a slogan. They really need to be monitored and for those who are not so familiar with all this, just consider in Glasgow, there was a call to end deforestation on the scale we see it today. The truth is 30% of the deforestation is illegal logging and that involves enormous corruption and that involves public officials as working together with organized crime. Raymond talked earlier about aspects of human trafficking and drugs. Again, we see public officials working together with organized crime, but at the same time, because this is global, we're talking about institutions in our countries in the North that are actively participating in this criminal activity. So the answer is yes, we do need, as Zoe has said, a truly transnational, and Alex has said, global approach. At the same time as Raymond has said, we really need to focus much, much more on the money itself and on all of the intermediaries and the suppliers. We must do things. Shareholder pressure will help on the climate change side, I'm sure, to a certain degree, but not sufficient. We need far greater transparency into the operations of all these institutions. And just one final point, Tom. I've been asked in connection with this new book a bit about why such a focus on the banks. J.P. Morgan Chase has more assets under management than the GNP of all the countries of the world except for the big four economies. It has more assets under management twice as much, in fact, than the total GNP of Russia. If you take the 10 top non-Chinese banks in the world, they all have multi-trillion dollar balance sheets. We're talking about vast Leviathans that to a very large extent are not nearly regulated enough, not nearly scrutinized enough. And unless there is public pressure on them in the environmental area, but in all these other areas, I'm afraid their cultures will not change and they must change to serve the interests of democracy and free markets itself. Thank you. Thanks, Rick. And I'll open that question up to the other three panelists. If anybody has any thoughts on ESG in connection with the banks or with any of the enablers that we've discussed today, whether it's the art market or private equity, the whole host of industries that probably should be using these more than they do. But anyone have any thoughts on this particular point? Not seeing any? Okay, that's fine. Well, you know, we're past the hour. Maybe we should call it there. Yes, Frank, last point. I just wanna make one final comment. I'd like to really thank you, Tom and thank the co-panelists here. I think this is a marvelous start to a conversation. I hope my book adds to the conversation. I'd also like to thank so many people who've tuned in today. These are my mentors. These are the people I look up to, like Uget LaBelle and Peter Eigen and Delia Ferrero-Rubio and Lawrence Cockroft and Francois Valerian and James Cohen and others that I could go on to mention. I'm incredibly grateful that they've tuned in today. And I know that all of us together can do so much more. And I'm really encouraged with a lot of what I've heard today. And I'm also encouraged by the interest in this book and in the challenges that I think we can make a difference at the Biden Summit and we can make a difference next year as that summit unrolls and the pressure mounts on country. So thank you so much, Tom. Thank you, Frank. Thank you to everyone who watched the presentations today. Thank you to our panelists Raymond, Alex and Zoe. Frank, this is a great addition to the literature. I know it's going to be important contribution. We look forward to future discussions about this very important issue. Thanks to everyone again. Enjoy the rest of your day. Thank you all.