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This article is part of Liberty Amplified, a series produced in partnership with the Hoover Institution’s Human Security Project and the Hoover Institution Library & Archives, featuring voices that challenge authoritarianism in pursuit of freedom. It concludes a three-part analysis of transnational financial repression, in which authoritarian regimes weaponize financial and legal systems beyond their borders to stifle the voices of advocates for liberty. To understand these pernicious means of oppression and how to counter them, see also “The Rise of Transnational Financial Repression” and “How Targeted Misinformation Stalks Its Victims.” — H.R. McMaster
For about five months in 2026, criminals used a forged European investigation order, sent from an authentic, certified e-mail address of an Italian prefecture office on the Interior Ministry’s domain, with Postal Police protocol numbers and in the name of the Milan prosecutor, to extract personal data from Revolut, a digital bank. About 680 customers lost passport IDs, selfies, home addresses, IBANs, and full transaction histories. The attackers used public blockchain data to identify high-value cryptocurrency clients, submitting hundreds of crypto transaction IDs and deposit wallet addresses as query keys. The files are now being published for ransom. At least one victim has received kidnap threats.
Revolut applied the one ground for refusal that EU anti-money-laundering (AML) law gives it— jurisdiction—and declined requests tied to UK and Swiss entities. But for accounts at Revolut Bank UAB in Lithuania, which were within the scope of the order, the law gave Revolut no basis to refuse and no duty to verify who was behind the authenticated state request. Refusal carries fines in the millions. Over-compliance carries no penalty. Any bank would have done the same.
The Revolut breach demonstrates what activists and civil society organizations have long argued: privacy of payments and communications must be recognized as a fundamental right in the digital age. What was once a concern mainly for dissidents, diaspora communities, and their donors now affects hundreds of ordinary customers of a Western financial institution.
The reform framework
Three major parliamentary bodies adopted formal positions on transnational financial repression in 2026.
The European Parliament resolution on countering transnational repression (2025/2179(INI)) recognized the misuse of Financial Action Task Force standards that target money laundering and terrorist financing (AML/CFT) to trigger compliance-based freezes and debanking. The Parliament called on the EU’s new Anti-Money Laundering Authority to introduce pre-freeze verification, victim-centered redress, and guaranteed access to basic banking.
The Parliamentary Assembly of the Council of Europe, in Resolution 2669, adopted amendments recognizing financial repression as a distinct category of transnational repression.
And the most operational set of proposals came from the Organization for Security and Cooperation in Europe (OSCE) Parliamentary Assembly, which in July adopted the Resolution on Countering Transnational Financial Repression and the Weaponization of INTERPOL, AML/CFT, and Cybersecurity, as part of the Hague Declaration.
The resolution calls on states to apply a rebuttable presumption of abuse to cooperation requests from states identified as enablers of transnational repression, starting with Russia. It proposes that states whose requests have been found abusive must provide redress, including correction of records and restoration of basic banking, before being permitted to submit further requests. And it calls on states in the Financial Action Task Force to incorporate binding human rights and fair-trial guarantees while adopting neutral terminology for privacy-enhancing tools like end-to-end encryption on which civil society legally relies.
How to safeguard the financial world
These resolutions establish the reform framework, but their implementation depends on US regulatory requirements which set international financial standards. Without US adoption of AML/CFT reform, parliamentary resolutions remain declarations without enforcement.
By leading the adoption of the OSCE resolution, the United States can develop effective remedies to hold perpetrators of transnational financial repression against American citizens and entities accountable, while strengthening the protection of privacy as a fundamental right in the digital age.
We propose the following policy options.
Establish a “red list” of jurisdictions under the monitoring of AML/CFT abuses. To establish credible deterrence mechanisms that prevent foreign governments and their proxies from exploiting the good-faith assumptions embedded in US financial, regulatory, and legal cooperation frameworks, we recommend creating a red list of jurisdictions. These would face tangible consequences, including restrictions or suspension of cooperation, rejection of foreign-origin allegations and legal requests, enhanced scrutiny, and other proportionate penalties, while green-listed jurisdictions would benefit from continued cooperation.
Create legal remedies to contest transnational financial repression and restore financial access. To enable wrongfully targeted individuals and organizations to contest allegations, we recommend creating clear legal pathways to correct contaminated customer risk profiles and restore access to financial services. These pathways would include enforceable mechanisms to ensure that judicial findings in democratic jurisdictions, including dismissals and findings of no wrongdoing, are meaningfully reflected in compliance databases and risk-assessment systems.
Establish a special license for high-risk entities and individuals. To protect individuals and entities that have been, or are at heightened risk of being, subjected to transnational financial repression, we recommend the creation of a special protective license for high-risk individuals and organizations. Based on a rigorous assessment of the individual’s risk profile and the credibility of foreign-origin allegations, this license would ensure continued access to financial services. In addition, we recommend clear limitations on the sharing of financial and personal data of a licensed person. Such measures should constrain the automatic extension of AML/CFT-based actions to family members, business partners, donors, and associates absent independent evidence.
Mandate annual congressional reporting on transnational financial repression risks and enforcement gaps. To improve oversight of trends, jurisdictions of concern, and gaps in existing safeguards, we recommend that the US Congress mandate a yearly report on these issues. We recommend that this report explicitly assess the collateral effects of AML/CFT enforcement on innocent third parties, the effectiveness of remedies for wrongfully targeted individuals, and patterns of domestic facilitation. Given the sensitive nature of this issue, we also recommend that the team of experts and whistleblowers involved in this report be afforded special protections by the US government.
Establish a transnational financial repression fusion cell. To coordinate detection, response, enforcement, and oversight efforts at the interagency level, we recommend that the US government establish a dedicated transnational financial repression fusion cell. This specialized task force would serve as the central mechanism for administering the jurisdictional evaluation system, coordinating corrective actions, engaging with regulated entities, and ensuring that remedies are consistently applied.
Protect and promote privacy tools as a fundamental right in the digital age. To protect individuals against transnational financial repression, we recommend that the US government safeguard access to privacy-preserving payment and communication technologies, including end-to-end encryption and Bitcoin. Reducing the data available to hostile states is among the most effective protections an individual has. After the 2024 Salt Typhoon breach, the FBI and the American cyberdefense agency, the CISA, urged Americans to adopt encrypted communications. Accordingly, we recommend that policy reject encryption backdoors and data-retention mandates that widen the channels exploited by authoritarian states.
Establish a transatlantic right to financial rehabilitation and recourse for the wrongly de-banked. To help individuals and organizations excluded from the financial system through politically motivated allegations clear their status and recover access, we recommend that the United States and the European Union create enforceable mechanisms for financial rehabilitation and recourse. Specifically, we recommend that policy establish an independent body empowered to
Examine the basis for a de-banking or de-platforming decision and to determine whether the client can be reinstated,
Guarantee affected persons the right to access, correct, or delete the data underlying an alert and to obtain compensation where warranted,
And ensure guaranteed access to basic banking and emergency liquidity for those credibly at risk, so that a politically driven freeze does not become a financial death sentence.
The European Parliament has already mapped this agenda and calls on the EU’s new Anti-Money Laundering Authority to build pre-freeze verifications, victim-centered redress, and guaranteed access to basic banking for those at risk. We recommend that these recognitions be translated into binding law in Europe and America with a long-term objective of a transatlantic convention on transnational repression.
Jorge Jraissati is a Venezuelan economist and the president of the Economic Inclusion Group, an international policy organization focused on protecting people and entities from debanking risks, supporting countries with their economic security, and advancing the reconstruction of the Venezuelan economy.
Lyudmyla Kozlovska is president of the Open Dialogue Foundation and a leading civil society voice on transnational repression and the weaponization of financial and security tools, which she frames as a national security threat to Western states, not only a human rights concern.
Liberty Amplified features the voices of those who defy autocracy in pursuit of freedom. It is produced in partnership with the Hoover Institution’s Human Security Project and the Hoover Institution Library & Archives.