This compendium of news reports about corruption and ethics issues is brought to you by the Center for Ethics and Public Integrity (CEPI). Neither the National Association of Attorneys General nor the National Attorneys General Training & Research Institute expresses a view as to the accuracy of news accounts, nor as to the position expounded by the authors of the hyperlinked articles.
NAAG Capital Forum: NAAG hosted its annual Capital Forum, which allowed state and territory attorneys general to engage with each other and federal officials, discuss important policy issues, and learn about the latest state and federal legal developments. The event included a panel discussing public integrity prosecutions. New Jersey Attorney General Matthew Platkin called on fellow state attorneys general to combat government corruption, as recent U.S. Supreme Court decisions have made federal corruption prosecutions more difficult. Delaware Attorney General Kathy Jennings, South Dakota Attorney General Mark Vargo, and Rhode Island Chief Deputy Attorney General Adi Goldstein also offered their perspectives, including about Percoco and Ciminelli, two cases recently argued before the U.S. Supreme Court that are summarized below. The event also included a panel discussing ethical challenges in high-profile cases, featuring Idaho Attorney General Lawrence Wasden as moderator, Former Professional Responsibility Officer and Government Ethics Advisor, U.S. Attorney’s Office, Southern District of New York John McEnany, Ohio Deputy Attorney General Charles Miller, and Senior U.S. District Judge Reggie Walton. Hamilton fans will appreciate the discussion near the end of the ethics panel. All sessions were recorded and will be available for viewing soon in NAAG’s video library.
State Gift Law Map and Summary Table: NAAG’s website offers an interactive map and sortable table displaying the types of statutes that govern when a public official may or may not accept a gift. The gift statutes apply to instances where a thing of value is given to an official without a clear quid pro quo and without adequate consideration given in return. They tend to fall into three different categories, which are shown in the map and table as: general restrictions, source-based restrictions, and intent-based restrictions. Many states have more than one type of gift restriction. CEPI welcomes any feedback on this new resource. Please contact Marissa Walker at email@example.com with comments or questions.
The Anticorruption Manual: A Guide for State Prosecutors: CEPI’s comprehensive Anticorruption Manual was published in August 2021. This is the first publication in thirty years to guide prosecutors who investigate and charge public corruption crimes. It is the first-ever book designed to address the needs of state and local corruption prosecutors. The book is available for purchase; members of the attorney general community should log into to their NAAG accounts to access a discount code, and other prosecutors should email Zayn Hasan at firstname.lastname@example.org for their discount code. A free sample chapter addressing judicial corruption is available for download. A series of articles further describes the purpose and contents of the manual.
Former Hillsdale Deputy Accepts Plea Deal for Misconduct: Todd Barkley, deputy sheriff in Hillsdale County, Michigan, pleaded guilty to misconduct in office for using his official position to coerce a woman into a sexual relationship. The coercion victim was in a substance abuse rehabilitation facility in Kentucky when Barkley used official position to allow her to leave the facility for the purpose of having sex with Barkley. This case was brought by the Michigan Attorney General’s Office.
Richard Rosen Arrested for Double Voting in 2016 Election, Officials Say: Richard Rosen, a resident of both Massachusetts and New Hampshire, was indicted on one count of wrongful voting. In the 2016 general election, Rosen allegedly voted in person in Massachusetts after casting an absentee ballot in New Hampshire. This case was brought by the New Hampshire Attorney General’s Office.
Merrimack Man Indicted on 2021 Special Election Interference Charge: Michael Drouin was indicted on one count of interference with election communications in relation to a special election in 2021. Drouin allegedly placed a false ad on Craigslist offering a free trailer and listing the cell phone number of one of the candidates in the election. The ad resulted in that candidate’s phone being overwhelmed with messages and calls. This case was brought by the New Hampshire Attorney General’s Office.
Philadelphia Man Charged for Forging 2019 Election Petitions: Rasheen Crews, a Philadelphia political consultant, was charged with criminal solicitation to commit forgery and theft by failure to make required disposition for forging signatures on nomination petitions on behalf of political clients seeking to be on the ballot for the 2019 primary races in Philadelphia. Multiple clients hired Crews to help them obtain the signatures needed for their nomination petitions. Crews hired other people to write names, addresses, and forged signatures on multiple petitions in a hotel room. Over one thousand signatures were duplicated on the petitions. Many names were repeated, some pages were photocopied entirely, and some of the individuals whose names were listed claimed that they did not sign the petitions at all. The case was investigated and charged by the Pennsylvania Attorney General’s Office.
Former SC Public Official Embezzled Thousands for Her Personal Use, Cops Say: Tina Marie Sullivan, a former clerk for the town of Pamplico, South Carolina, was charged with embezzlement of public funds for using the town credit card for personal transactions in the amount of over $9,000.
Spokane County Worker Admits to $1.38M Theft Involving Fake Liability Claims: Rhonda Sue Ackerman, a former liability claims technician for Spokane County, Washington, pleaded guilty to one count of first-degree theft. Ackerman stole $1.38 million over a decade by filing false claims involving her friends and family members as claimants. After Ackerman filed the false claims, checks would be sent to the fraudulent claimants and Ackerman would direct them to cash the checks and give her the bulk of the funds. The Washington State Auditor’s office began investigating when it discovered an uncashed check for nearly $9,000. The investigation revealed that Ackerman devised the check-cashing scheme to support a gambling habit. The Washington Attorney General’s Office took over the prosecution from the Spokane County Prosecutor, who referred the case to avoid a potential conflict of interest because Ackerman was a county employee.
Former JBER Contract Specialist Sentenced for Bribery: Brian Lowell Nash II, former U.S. Air Force contract specialist at Joint Base Elmendorf-Richardson (JBER) in Alaska, was sentenced to 30 months in prison and ordered to forfeit $47,000 in unlawful gains. Nash agreed to accept more than $460,000 in bribe payments from the owner of a government construction contractor. At the time he was caught, Nash had received only $47,000 of those bribes. In exchange, Nash gave the contractor confidential bidding information on over $ 8 million in defense contracts, which helped the contractor win those contracts. Nash previously pleaded guilty to conspiracy and acceptance of bribes by a public official.
20 People, Including Employees, Convicted in California DMV Corruption Cases: Twenty defendants, including California Department of Motor Vehicle (DMV) employees, owners of trucking schools, and various other co-conspirators, were convicted of various crimes including bribery of public officials, identity fraud, unauthorized access of computers, and conspiracies to commit those offenses. The conduct occurred in various locations throughout California. The scheme involved DMV employees accepting bribes to enter fraudulent test scores for applicants for commercial licenses who either had never taken licensing tests or who could not pass the test. Hundreds of fraudulent commercial licenses were issued as a result of the scheme. Individual defendants and the sentences they received are listed on the U.S. Department of Justice website.
Fake Law Enforcement ‘Consultant’ Sentenced for Role in Former Sheriff’s Captain’s Corruption Scheme: Waiel Anton, who claimed to be an honorary law enforcement official under former San Diego County (California) Sheriff’s Captain Marco Garmo, was sentenced to 12 months and a day in prison after previously pleading guilty to two counts of obstruction of justice. Anton collected cash payments from the operator of unlicensed marijuana dispensaries in exchange for giving advance warning about planned law enforcement searches of the businesses. Sheriff’s Captain Garmo previously pleaded guilty to unlicensed firearms trafficking.
Ex-DeKalb Commissioner Sharon Barnes Sutton Convicted of Extortion: Sharon Barnes Sutton, former commissioner of the DeKalb County (Georgia) Board of Commissioners, was convicted of two counts of extortion. Sutton extorted a subcontractor that had a $1.8 million contract with the county by demanding monthly payments of $500. Sutton later increased the demand to $1,000 per month. She also accepted $5,000 from a confidential informant. At the time that she accepted the payments, Sutton was already being investigated for misusing a county purchasing card.
Ex-Hawaii Guard Sentenced to 12 Years for Assaulting Inmate: Jonathan Taum, former supervisory correctional officer at the Hawaii Community Correctional Center, was sentenced to 12 years in prison for his role in supervising and encouraging an assault on a non-violent inmate and for a cover-up conspiracy. The cover up included writing false reports, making false statements to internal affairs, and falsely testifying to disciplinary board members.
Former Cook County Land Bank Authority Worker Charged with Property Scam: Mustafaa Saleh, former employee of the Land Bank Authority in Cook County, Illinois, was charged with one count of wire fraud. Saleh worked as an asset manager for the Lank Bank Authority, which was intended to redevelop and reuse vacant, foreclosed, abandoned, and tax delinquent properties. Employees of the land bank were prohibited from purchasing a property from the agency unless the employee used it for the employee’s primary residence. Saleh allegedly used straw buyers to purchase six properties from the Land Bank Authority, redeveloped them, and sold them for his personal financial benefit.
Former State Police Union Head Dana Pullman, Lobbyist Anne Lynch Convicted of Racketeering, Fraud: Dana Pullman, former president of the State Police Association of Massachusetts (SPAM), and Anne Lynch, former lobbyist, were convicted of one count of racketeering conspiracy, one count of honest services wire fraud, three counts of wire fraud, one count of obstruction of justice and one count of conspiracy to defraud the Internal Revenue Service. Pullman was convicted of two additional counts of wire fraud and two counts of aiding and assisting the filing of a false tax return. Lynch was convicted of an additional count of obstruction of justice and four counts of aiding and assisting in the filing of a false tax return. SPAM is the exclusive bargaining agent representing troopers and sergeants from the Massachusetts State Police. While Pullman was the president of SPAM, Lynch’s lobbying firm represented SPAM. Pullman and Lynch used SPAM as a racketeering enterprise through various acts including Lynch paying Pullman a $20,000 kickback from a settlement agreement between SPAM and the Commonwealth of Massachusetts; Pullman directing vendors to use Lynch’s services; and concealing payments made by Lynch and her firm to Pullman to avoid reporting and paying taxes. Lynch and Pullman obstructed a grand jury investigation into their conduct. Pullman also embezzled SPAM funds for his personal use.
Former Tribal Leader Gets 3 Years in Casino Bribery Case: Cedric Cromwell, former chair of the Mashpee Wampanoags in Massachusetts, was sentenced to three years in prison after being convicted in May 2022 of bribery and extortion. Cromwell accepted bribes from David DeQuattro, the owner of an architectural firm that was working with the tribe to build a casino. DeQuattro was sentenced to a year of probation. Cromwell has appealed the sentence.
Ex-Sheriff Terry Grassaree, Ex-Deputy Indicted for Bribery, Lying to FBI: Terry Grassaree, former sheriff of Noxubee County, Mississippi, was indicted on one count of bribery and one count of giving a false statement to a federal agent. Vance Phillips, Grassaree’s deputy, was indicted on one count of bribery. Grassaree and Phillips allegedly gave a former inmate special privileges in exchange for sex or sexually graphic videos.
Canton City Officials, Former Canton City Engineer, Indicted in Bribery Scheme: Two officials from the City of Canton, Mississippi, Eric Gilkey and Andrew Grant, pleaded guilty to conspiracy to commit bribery. They were indicted along with two additional defendants: Canton’s former city engineer Rudolph Warnock and former Board Commissioner for Canton Municipal Utilities Cleveland Anderson, who have pleaded not guilty. Warnock is charged with two counts of conspiracy to commit bribery, one count of conspiracy to commit wire fraud, and one count of wire fraud. Anderson is charged with two counts of conspiracy to commit bribery. Warnock allegedly gave benefits such as cash, concert tickets, and sports tickets to Anderson, Gilkey, and Grant in exchange for favorable treatment in awarding city engineering contracts to Warnock.
Three DOC Officers Charged with Fraud for Lying About Sick Leave for Over a Year: Three New York City Department of Corrections officers, Steven Cange, Monica Coaxum, and Eduardo Trinidad, were charged with federal program fraud for engaging in a scheme to stay on sick leave for over a year. The defendants received their full pay while taking sick leave based on numerous allegedly fraudulent medical notes. The defendants were also allegedly observed engaging in normal activities without any medical difficulties.
Ex-Director of Food Services at Hempstead Schools Pleads Guilty to $120K Kickback Scheme: Sharon Gardner, food service director for Hempstead Union Free School District on Long Island, New York, pleaded guilty to conspiracy to commit honest services for participating in a kickback scheme in which Gardner accepted more than $120,000 from Maria Caliendo, the owner of food service providers, in exchange for a no-bid contract for food services. Overall, Gardner steered more than $1 million in school breakfast contracts to Caliendo even though more cost-effective options were available. Caliendo previously pleaded guilty.
Corruption Charges Dismissed Against Ex-New York Lieutenant Governor; U.S. Appeals: A U.S. District Court dismissed charges of bribery, honest services wire fraud, and conspiracy that were brought against former New York Lieutenant Governor Brian Benjamin. The charges were based on Benjamin directing a $50,000 state grant to a charity run by Gerald Migdol allegedly in exchange for campaign contributions from Migdol to Benjamin. The court ruled that the Department of Justice failed to allege an explicit quid pro quo between Benjamin and Migdol. Two falsification of records charges remain against Benjamin. Migdol previously pleaded guilty to bribery and fraud.
Meals, Concerts and Pope Francis Visit Part of Ex-SEPTA Manager’s Alleged Bribes: James Stevens and Robert Welsh were indicted on charges of conspiracy, bribery, extortion, and fraud. Stevens was the Director of the Video Evidence Unit with the Southeastern Regional Transportation Authority (SEPTA) in Philadelphia, Pennsylvania. Welsh was the owner and operator of a company that installed, maintained, and supplied video surveillance equipment for SEPTA. Stevens allegedly demanded from Welsh a variety of financial benefits in exchange for Stevens helping to maintain and grow Welsh’s business with SEPTA, which was worth millions of dollars. The benefits Welsh gave included cash, fraudulent charitable donations for Stevens’ personal benefit, lodging and meals during the 2015 Papal visit to Philadelphia, meals and drinks, concert tickets, and funds for SEPTA annual holiday parties, as well as promised future employment when Stevens retired from SEPTA.
Ex-Sen. Brian Kelsey Pleads Guilty to Two Counts of Federal Campaign Finance Violations: Former Tennessee State Senator Brian Kelsey pleaded guilty to conspiracy to defraud the Federal Election Commission and aiding and abetting the acceptance of excessive contributions on behalf of a federal campaign. Kelsey conspired to transfer money from his state senate campaign and from a nonprofit corporation to a political organization for the purpose of funding advertising for Kelsey’s U.S. Senate campaign. He also caused the political organization to make coordinated expenditures to Kelsey’s federal campaign committee.
Former Houston Health Department Worker Admits Taking Part in Kickback Scheme: Barry Barnes, a former administrative and community outreach coordinator for the Houston (Texas) Health Department, pleaded guilty to bribery concerning programs receiving federal funds. Barnes used his position to engage in a kickback scheme where Barnes selected specific businesses to perform marketing and advertising services for the health department and, in exchange, Barnes received cash payments.
Lyford Man Indicted on Allegations of Federal Bribery, Extortion: Patrick Gorena, a former border investigator for the U.S. Department of Transportation in Texas, was indicted on charges of one count of bribery and one count of extortion under color of law. While serving as a border investigator, Gorena allegedly minimized purported safety violations he encountered while auditing a trucking company and demanded a $3,500 payment in exchange. Gorena allegedly accepted a $2,000 bribe from an undercover law enforcement officer.
GOP Operative Pardoned by Trump Convicted of Funneling Russian Money to Trump Campaign: Jesse Benton, a former congressional aide and Texas resident, was convicted by a jury of conspiring to solicit and cause an illegal campaign contribution by a foreign national, effecting a conduit contribution, and causing false records to be filed with the Federal Election Commission. Benton helped a Russian citizen illegally funnel a political donation to a 2016 presidential campaign. Benton concealed the Russian national’s citizenship from the campaign and the candidate, but he helped the individual attend a political fundraising event and take a picture with the candidate. To do so, the Russian national paid Benton $100,000 in exchange for Benton purchasing a $25,000 ticket to the event under Benton’s name. Benton kept the remaining $75,000.
Missouri Supreme Court Rules that Former Prosecutor Amy McGowan Will Face No Discipline: Amy McGowan, a retired prosecutor who served in Douglas County, Kansas, and Jackson County, Missouri, will not have her law license suspended by the state of Missouri for her conduct in prosecuting a man who spent 23 years in prison and who was later exonerated in 2019. McGowan had been accused of withholding evidence in that case and of redacting pertinent medical information in a different case that was overturned in 2021. McGowan was accused of previous instances of misconduct in other cases.
Disbarment for Obstruction of Justice: Sylvia Ash, a former judge in New York, was disbarred after having been convicted by a federal jury of conspiracy to obstruct justice, obstruction of justice, and making a false statement to federal officers and sentenced to 15 months in prison. Ash’s obstruction occurred in the context of a federal investigation of the former chief executive officer of a bank, Municipal Credit Union (MCU), who had received millions of dollars from that bank. Ash was the chair of the board of directors of MCU. In the course of that investigation, Ash made false statements to investigators, concealed and deleted text and email messages, and deleted data from her personal electronic device.
San Diego Defense Contractor Sentenced for Selling Information to Chinese Government: Shapour Moinian, a defense contractor and former U.S. Army helicopter pilot based in San Diego, California, was sentenced to 20 months in prison for acting as an agent of China and accepting thousands of dollars in bribes in exchange for giving American technology and intellectual property to China. Moinian served in the army from 1977 to 2000. After serving in the army, he worked for various “cleared” defense contractors, which means that the contractor is permitted to work with classified information. While working for a cleared defense contractor, Moinian traveled overseas several times, met with individuals employed or directed by the government of China, and gave those individuals proprietary aviation-related information. In exchange, those individuals gave Moinian various cash payments, deposits into bank accounts held by Moinian’s stepdaughter, as well as a cell phone and other communication equipment. Moinian smuggled the cash payment back into the United States and lied on his government questionnaires regarding contacts with foreign nationals. Moinian pleaded guilty to acting as an agent of a foreign government and making false statements.
Double Recidivist ABB Pays $462.5 Million to Settle FCPA Offenses: ABB Ltd., a Swiss-based global technology company, entered into a three-year deferred prosecution agreement (DPA) with the U.S. Department of Justice in connection with a criminal information against ABB in the Eastern District of Virginia, which charged ABB Ltd. with conspiracy to violate the anti-bribery provisions of the Foreign Corrupt Practices Act (FCPA), conspiracy to violate the FCPA’s books and records provisions, and substantive violations of the FCPA. ABB Ltd. was previously charged with and settled FCPA offenses in 2010 and 2004. Subsidiaries of ABB—ABB Management Services Ltd. (Switzerland) and ABB South Africa (Pty) Ltd. (South Africa)—also each pleaded guilty to one count of conspiracy to violate the anti-bribery provisions of the FCPA. Under the DPA, ABB’s total criminal penalty is $315 million, which may be reduced up to one half depending on amounts ABB will pay to the Securities and Exchange Commission, South African authorities, and authorities in Switzerland and Germany. ABB’s underlying conduct was that it paid bribes to South African government officials in exchange for business advantages and conducted sham negotiations to inflate contract prices. The SEC resolved a related civil case against ABB through an administrative order that imposed a penalty of $75 million and disgorgement of $72.5 million.
Yan, Zhou Plead Guilty to Conspiring to Bribe Marshall Islands Officials: Cary Yan and Gina Zhou, pleaded guilty to conspiring to violate the Foreign Corrupt Practices Act. Yan and Zhou bribed Marshall Islands government officials to pass legislation that would benefit Yan and Zhou’s business interests, including allowing the couple to establish an autonomous mini-state in the Marshall Islands. Yan and Zhou carried out the alleged scheme while in New York, and other locations within the United States. Yan and Zhou are not U.S. citizens. They were arrested in Thailand and were extradited to the United States.
Former Senior U.S. Navy Employee Sentenced for Bribery Conspiracy and Lying to Investigators: Xavier Fernando Monroy, former Director of Operations of the U.S. Navy’s Military Sealift Command in Busan, South Korea, was sentenced to 5 years in prison for his role in a bribery conspiracy and lying to federal investigators. Monroy was convicted by a jury in August 2022 of conspiracy to commit bribery, bribery, and making false statements. Monroy used his official position to steer over $3.3 million in service contracts for U.S. military ships to a company, DK Marine, in exchange for bribes of thousands of dollars in cash, travel, meals and alcoholic beverages, and prostitution services. Monroy also gave confidential and proprietary military information in exchange for the bribes. When interviewed by federal agents, Monroy lied about his conduct.
Feds Rip Orange County’s Use of Jailhouse Informants: The U.S. Department of Justice, in a written report, found reasonable cause to believe that the Orange County (California) District Attorney’s Office (OCDA) and Orange County Sheriff’s Department (OCSD) violated the Sixth Amendment and Fourteenth Amendment by using jailhouse informants to elicit incriminating statements from people who had been arrested, after those individuals had been charged with a crime, and by failing to disclose exculpatory evidence about those custodial informants to criminal defendants. OCDA and OCSD stopped using informants as agents of law enforcement to obtain statements from charged defendants in the Orange County Jail in 2016, when the DOJ opened its investigation.
‘You Mean We Have to Feed These People?’ Remark Part of Judge’s ‘Habitual Intemperance,’ Ethics Complaint Says: Robert Reeves, the chief judge for the Georgia Middle Judicial Circuit Superior Court, is the subject of an ethics complaint filed by the Georgia Judicial Qualifications Commission. Reeves is accused of making improper and intemperate comments, some of which manifested bias, prejudice, and gender-based sexual harassment. When inmates in his courtroom needed a lunch break, Reeves commented, “You mean we have to feed these people?,” visibly upsetting supporters in the courtroom. He is also accused of having improper contact with court personnel and improperly participating in fundraising.
Clergy Abuse Survivors Disappointed in Court Ruling Preventing Public Release of Archdiocese Investigation: The Maryland Attorney General’s Office moved to release its nearly 500-page report regarding clergy abuse in Maryland involving the Archdiocese of Baltimore. The report identifies over 600 victims, but does not contain victim names or any identifying information. A Baltimore circuit court denied the motion, ruling that no party is allowed to share any filing or communication, with any non-party to the proceedings. The Archdiocese of Baltimore has stated that it does not oppose the release of the report, but it is also reportedly paying legal fees of the anonymous group opposing its release.
Which Police in Your Town Have Used Excessive Force? NJ Expands Access to That Info: The New Jersey Attorney General Matthew J. Platkin issued a directive increasing disclosures of police internal affairs information. The new policy expands the 2020 policy that required agencies to report synopses of major discipline (termination, demotion, or suspension of more than 5 days). The new policy further requires annual reporting of specific categories of misconduct, regardless of the severity of discipline imposed. The categories are discrimination or bias, excessive force, untruthfulness or lack of candor, false report or certification, intentionally improper search, seizure, or arrest, intentional mishandling of evidence, and domestic violence. The information will be reported to the Attorney General’s Office and published on each law enforcement agency’s website.
U.S. Supreme Court Leans Toward Limiting Public Corruption Prosecutions: The U.S. Supreme Court heard oral argument in Percoco v. United States and Ciminelli v. United States. In Percoco, the defendant is Joseph Percoco, a friend and senior aide to former New York Governor Andrew Cuomo. While Percoco worked on Cuomo’s reelection campaign and held no formal elected office or government employment, he accepted money through his wife in exchange for using his influence to further the interests of an energy company and a real estate company. Shortly after accepting the money, Percoco returned to his job in the governor’s office. The issue is whether a private citizen who holds no elected office or government employment but has informal political or other influence over governmental decision-making, owes a fiduciary duty to the general public such that he can be convicted of honest-services fraud. The Second Circuit decided that such a private citizen can be convicted of honest-services fraud. In Ciminelli, the defendant is Louis Ciminelli, a construction company executive who was convicted of wire fraud for rigging bids on a project to revitalize the Buffalo, New York area. The issue is whether the “right to control” theory of fraud states a valid basis for a federal wire fraud charge. That theory considers it property fraud to deprive a person making an economic decision of complete and accurate information bearing on that decision. NAAG Supreme Court Reports summarized the Percoco and Ciminelli cases when the Supreme Court granted review. The Global Anticorruption Blog also discussed the Percoco case.
White House Announces “Full Support” for Critical Bipartisan Anti-Money Laundering Reform Bill at Anti-Corruption Conference: The Biden Administration has stated its full support for the Establishing New Authorities for Business Laundering and Enabling Risks to Security (ENABLERS) Act. The ENABLERS Act would broaden the Bank Secrecy Act’s definition of “financial institution” and would empower the U.S. Treasury Department to require adoption of basic anti-money laundering protocols by accountants, lawyers, investment advisors, and other non-bank financial service providers that perform acts such as forming companies, administering trusts, and managing money for a third party. The American Bar Association (ABA) has opposed the ENABLERS Act, arguing that it could require lawyers to report attorney-client privileged and other protected client information to the government. The Global Anticorruption Blog has a detailed response to the ABA’s objections. In the past, state attorneys general have supported other federal anti-money laundering measures such as the Corporate Transparency Act and the Improving Laundering Laws and Increasing Comprehensive Information Tracking of Criminal Activity in Shell Holdings (ILLICIT CASH) Act.