On December 6, 2021, President Biden issued the first United States Strategy on Countering Corruption to meet the grave threat transnational corruption poses to U.S. national security. The Strategy resulted from an interagency study the President mandated when he made combating corruption a core U.S. priority in his first National Security Study Memorandum. Organized in five pillars, the Strategy establishes specific lines of work to support people and institutions that fight corruption, direct action against corrupt actors, and impede corrupt actors’ abuse of our financial system. Some of the many steps taken under the Strategy are outlined below.
Pillar One: Modernizing, Coordinating, and Resourcing U.S. Efforts to Fight Corruption
We have taken significant action to align U.S. government authorities and policy and to increase intra- and inter-agency coordination to counter corruption threats. Efforts have included:
- The Department of State appointed its first Coordinator on Global Anti-Corruption and created a senior-level Anti-Corruption Policy Board to mainstream and prioritize anti-corruption in foreign policy. The Departments of the Treasury and of Commerce, and the U.S. Agency for International Development (USAID), have each set up or used existing coordinating bodies to enhance anti-corruption efforts internally and externally, and the Development Finance Corporation added a senior integrity and anti-corruption advisor.
- USAID issued its first Anti-Corruption Policy to prioritize anti-corruption across programs, redirect efforts toward the most damaging forms of corruption, forge new partnerships and coalitions, and safeguard assistance resources. USAID held an Anti-Corruption and Evidence Learning week and issued new guidance and resources to staff and partners, including a Dekleptification Guide targeting entrenched corruption, a Guide to Countering Corruption Across Sectors, and a handbook on countering corruption in the global health sector.
- The State Department and USAID made anti-corruption a resource and personnel priority in the 2022-2026 Joint Strategic Plan; increased staff dedicated to anti-corruption initiatives; and invested in capacity building, including through expert training and guidance to staff.
- The Department of Justice, in its 2022-2026 Strategic Plan, prioritized combating corporate corruption and advancing international anti-corruption efforts and partnerships with foreign authorities. Justice Department operational offices and the Federal Bureau of Investigation deployed dedicated resources to investigate and prosecute domestic and foreign corruption.
- The Commerce Department trained over 100 U.S. and Foreign Commercial Service and other International Trade Administration (ITA) staff on the Foreign Corrupt Practices Act and related instruments, and on anti-corruption in international trade law.
- The Departments of State and Defense established an interagency Security Sector Governance Working Group to better integrate security sector governance standards into security cooperation and assistance planning processes and to strengthen protocols for assessing and mitigating corruption risk.
Looking ahead, further action will include efforts to direct and integrate resources by refining context-specific, inclusive goals and identifying strengths and gaps. USAID will create a Bureau for Democracy, Human Rights, and Governance with a dedicated Anti-Corruption Center.
Pillar Two: Curbing Illicit Finance
We have acted to address vulnerabilities in the U.S. and international financial systems that corrupt actors exploit to launder and hide corrupt payments and proceeds. Efforts have included:
- The Treasury Department advanced efforts to implement the Corporate Transparency Act (CTA) and prevent criminals from using shell and front companies to launder illicit proceeds by issuing a final rule that requires certain entities to report information about their beneficial owners—the person(s) who ultimately own or control them—to the Financial Crimes Enforcement Network (FinCEN); as well as a proposed rule on disclosure of that information to federal agencies, state, local, tribal and foreign governments, and financial institutions.
- FinCEN issued an advisory on kleptocracy and foreign corruption to help U.S. financial institutions better identify and report possible corruption-related transactions.
- The State Department and USAID, with civil society, launched a multi-stakeholder Financial Transparency and Integrity “democracy cohort” under the Summit for Democracy to spur action and encourage implementation of commitments to prevent corruption.
- The Justice and State Departments and federal law enforcement have reinforced cross-border partnerships, including through international asset recovery networks and the U.N. Global Operational Network of Anti-Corruption Law Enforcement Authorities (GlobE).
Looking ahead, curbing illicit finance will remain a priority. Further actions will include continued Treasury Department efforts to implement the CTA, enhance the transparency of the U.S. real estate sector, and assess the illicit finance risks associated with key financial gatekeepers, such as investment advisors, lawyers, and accountants. Also, through foreign assistance, the United States will further expand partners’ capacity against illicit finance.
Pillar Three: Holding Corrupt Actors Accountable
We have taken decisive measures to hold corrupt actors accountable through both independent and coordinated action with our international partners. This line of effort has included:
- The Treasury Department designated dozens of individuals and entities for their involvement in corruption, including current or former officials in Central America, Africa, the Western Balkans, and Eastern Europe. Further, the State Department publicly imposed visa restrictions on over 80 current and former foreign officials and immediate family members generally rendering them ineligible for U.S. entry based on significant corruption, and others under the Northern Triangle-United States Enhanced Engagement Act. To expand the impact of these tools, we coordinated with foreign partners through initiatives like the Democracies Against Safe Havens (DASH) Initiative, and advised foreign governments on adopting similar authorities.
- Justice Department, federal law enforcement, Securities and Exchange Commission, and Commodity Futures Trading Commission enforcement actions involving international bribery resulted in guilty pleas by multinationals or subsidiaries, penalties and forfeitures of over a billion dollars, and imposition of compliance monitors. Other notable convictions in foreign corruption and money laundering cases included a former Goldman Sachs officer in a multi-billion-dollar scheme, and a former Venezuelan national treasurer and her husband in a billion-dollar scheme. The Justice Department repatriated to Nigeria $20 million of forfeited corruption funds and initiated other civil actions to recover foreign kleptocracy proceeds.
- Justice Department and federal law enforcement peer-to-peer advisors, and State Department and USAID technical assistance programs, helped other countries strengthen their anti-corruption systems or adopt an anti-corruption strategy and legislation. These foreign authorities have secured landmark convictions, recovered millions of dollars’ worth of stolen assets, and produced high-quality investigations and prosecutions, among other results.
- The United States, in coordination with foreign partners, launched the Russian Elites, Proxies, and Oligarchs (REPO) Task Force to hold accountable those responsible for and benefitting from Russia’s brutal war on Ukraine. REPO member governments have frozen more than $30 billion in assets beneficially owned by sanctioned Russian parties.
- The Justice Department and federal law enforcement also launched the interagency Task Force KleptoCapture, which investigates violations of sanctions, export restrictions, and economic countermeasures imposed in response to Russia’s unjustified war. The Task Force has obtained over 30 indictments against oligarchs, facilitators, and professional enablers, as well as against smuggling networks attempting to illegally ship sensitive technologies to Russia. Working with international partners, the Task Force has seized over $500 million in assets, including investment accounts, real estate, and yachts. In February 2023, the Task Force forfeited $5.4 million tied to a Russian oligarch that the Attorney General has since authorized be transferred to the State Department to be used for remediation in Ukraine.
- The Treasury Department, in coordination with the Justice and State Departments, launched the Kleptocracy Asset Recovery Rewards Program, which offers to pay up to $5 million for information leading to the restraint or recovery of certain assets linked to foreign corruption.
Looking ahead, we will continue to use financial sanctions, visa restrictions, and, where appropriate, criminal, civil, or administrative enforcement actions against corrupt actors; and we will strengthen coordination with international partners and civil society to maximize our impact in countering kleptocracy, state capture, and strategic corruption.
Pillar Four: Preserving and Strengthening the Multilateral Anti-Corruption Architecture
We have forged alliances with like-minded governments to strengthen the multilateral infrastructure necessary to counter corruption across borders. Examples from the year include:
- The United States secured consensus of the 189 parties to the United Nations Convention Against Corruption (UNCAC) to host the 10th Conference of States Parties (COSP) in 2023.
- The United States cohosted the biennial International Anti-Corruption Conference with Transparency International, fostering global exchange and partnership among more than 2200 participants from government, civil society, and business in over 80 focused sessions.
- The United States launched a process to establish an Indo-Pacific Economic Framework for Prosperity (IPEF) with support among all 14 countries for a pillar on tax and anti-corruption, including measures to prevent and combat corruption and to enhance transparency in real estate transactions and beneficial ownership.
- The United States continued robust participation as a member state of the Group of European States Against Corruption (GRECO), including by increasing financial support following Russia’s expulsion and by offering subject matter experts to serve on evaluation teams.
- The United States joined 43 partners to issue a Revised Recommendation for Further Combating Bribery of Foreign Public Officials in International Business Transactions in the Organization for Economic Co-operation and Development (OECD) Working Group on Bribery, and promoted ethical business practices in the Asia-Pacific through the APEC Business Ethics for Small and Medium Enterprises Forum.
- The United States launched its 5th National Action Plan in the Open Government Partnership (OGP) to advance transparency, accountability, and public participation, and was recently elected to the OGP Steering Committee where it will further promote these principles abroad. USAID and the State Department also supported foreign and international multi-stakeholder initiatives, such as OGP and the Extractive Industries Transparency Initiative (EITI).
- The Departments of State and Defense increased collaboration with the North Atlantic Treaty Organization (NATO) Building Integrity program and have begun identifying opportunities to assist Allies and partners to devise mechanisms to increase transparency within their defense sectors. Other Department of Defense programming has enhanced accountability in partner defense resource management.
- The United States and its partners in the Financial Action Task Force (FATF) included commitments to combat corruption in the 2022 FATF Ministerial Declaration, and the FATF agreed to undertake projects to promote implementation of the UNCAC and address corrupt actors’ misuse of citizenship-by-investment programs and poorly-regulated gatekeepers.
Looking ahead, the United States will continue to forge multilateral alliances against corruption, including as a host of the Second Summit for Democracy and the 2023 UNCAC COSP; will support updated EITI Standards on beneficial ownership and transparent revenue disclosure; and will undergo a GRECO evaluation of U.S. anti-corruption systems in 2023; among other actions.
Pillar Five: Improving Diplomatic Engagement and Leveraging Foreign Assistance
We have scaled up assistance and diplomacy to fortify foreign governments against corruption; increased collaboration among governments, civil society and business; and invested in protecting those who work to expose corruption. Examples include:
- USAID launched Reporters Shield, an insurance product to defend journalists, media outlets and organizations from spurious lawsuits, as well as the Strengthening Transparency and Accountability through Investigative Reporting program to support investigative journalism networks and safety. The State Department fostered journalist and civil society collaboration by increasing investment in the Global Anti-Corruption Consortium, supported budget transparency through a Fiscal Transparency Innovation Fund, and recognized courageous leaders through the Anti-Corruption Champions Award program.
- The State and Treasury Departments, to spark innovation, developed an Anti-Corruption Solutions through Emerging Technologies initiative, launched in a multi-day Global Anti-Corruption Tech Sprint, and also hosted local TechCamps in South Africa, Argentina and Indonesia. USAID launched the Countering Transnational Corruption Grand Challenge for Development, including its Powering a Just Energy Transition Green Minerals Challenge.
- The State Department developed the Global Initiative to Galvanize the Private Sector as Partners in Combating Corruption (GPS) to advance public-private dialogue and action.
- The State and Justice Departments deployed a rapid response program for U.S. government experts to advise justice-sector counterparts, including through assessments and development of anti-corruption workplans in Czechia, Namibia, and the Democratic Republic of the Congo (DRC). USAID’s Anti-Corruption Response Fund piloted new assistance approaches in the Dominican Republic and the DRC. The State Department funded regional Anti-Corruption Hubs to promote practices in line with international standards and UNCAC.
- The Defense Department increased its investment in Institutional Capacity Building (ICB) programming that contributes to anti-corruption objectives. The State Department’s Global Defense Reform Program has provided ICB partners with strategic-level advisory support to enhance partner security sector governance, such as to Kosovo’s Ministry of Defense.
- The State and Justice Departments, and federal law enforcement agencies participated in worldwide anti-corruption trainings that facilitate law enforcement partnerships, cooperation, and information-sharing among countries around the world.
Looking ahead, diplomatic and foreign assistance efforts will include working in partnership with foreign partners to advance the Blue Dot Network in order to increase transparency, reduce corruption, and mobilize private capital for infrastructure investment in emerging economies; issuance of a Reference Guide to USAID Anti-Corruption Operational Safeguards that will highlight measures to ensure integrity in U.S. foreign assistance; and other initiatives.