White House publishes the “United States Strategy on Countering Corruption”

On December 6, 2021, the White House published the first “United States Strategy on Countering Corruption” (“Strategy”).

The Strategy derives from the review process, initiated following the publication of the Memorandum on Establishing the Fight Against Corruption as a Core United States National Security Interest”, conducted with the aim of developing a coordinated national strategy to fight corruption.

According to the Strategy, to curb corruption and its effects, the U.S. government will  organize its efforts around five pillars of work: (i) modernizing, coordinating, and resourcing efforts to fight corruption; (ii) curbing illicit financing; (iii) holding corrupt actors accountable; (iv) preserving and strengthening the multilateral anti-corruption architecture; (v) improving diplomatic engagement and leveraging foreign assistance resources to advance policy goals.

Across all five strategic pillars, the United States is committed to: (i) consulting on and coordinating efforts with representatives of civil society, the private sector, international and multilateral organizations, government partners, researchers, and Congress; (ii) prioritizing efforts to reduce corruption as a national security concern, elevating anti-corruption efforts through bilateral and multilateral diplomatic engagements, and encouraging U.S. states and local jurisdictions to redouble their efforts to fight corruption in parallel with federal action; and (ii) continuously assessing and refining its approach through the initiative in order to respond to new challenges and opportunities.

The document also introduces a series of efforts to achieve the strategic goals of each of the five pillars mentioned above. Broadly, the cooperation between government agencies and the U.S. Federal Government and international cooperation are cited as valuable resources to the achievement of the strategic goals. Please find below an overview of what it presented regarding each of the five pillars.

For the first pillar, related to resources to fight corruption, one of the efforts mentioned is seeking greater transparency for the U.S. campaign finance system, including with the aim of preventing undue influences in U.S. elections.

Regarding efforts for the second pillar, related to curbing illicit financing, the document mentions the enhancement of transparency to identify final beneficial owners of legal entities and the advancement of oversight of operations in tax havens, among other areas of risk, with the aim of countering money laundering. The document also mentions the need to enhance efforts to retrieve funds and the implementation of preventive measures.

Concerning the pillar for holding corrupt actors accountable, the document mentions the need to enhance civil and criminal legislation, as well as investigation tools. As an example, the document references the fact that the Department of Justice (“DOJ”) expanded its reach when seeking financial information kept in foreign territories. Additionally, the U.S. government will commit to holding the demand side of bribery accountable through international cooperation in countries where the bribery occurs. The international cooperation related to transnational criminal acts is also mentioned, including through sharing of information between governments partners and joint investigations.

Regarding the pillar for strengthening the anti-corruption architecture, the document mentions efforts in developing anticorruption measures in international financial institutions and the creation of global anticorruption partnerships and platforms.

Lastly, the document mentions efforts related to the fifth pillar, as regards diplomatic cooperation and foreign assistance. The fight against corruption is mentioned as a priority in the U.S. diplomatic discourse, and as a factor to be incorporated in other U.S. programs for assistance, including global health and humanitarian aid.

Demarest’s Compliance and Investigations team is available to provide further information on this and other related matters.