In a recently issued Presidential Memorandum, the Biden Administration declared that the fight against international corruption is a core national security interest of the United States. The memorandum begins by noting that “Corruption corrodes public trust; hobbles effective governance; distorts markets and equitable access to services; undercuts development efforts; contributes to national fragility, extremism, and migration; and provides authoritarian leaders a means to undermine democracies worldwide.” The memorandum states further that “Corruption threatens United States national security, economic equity, global anti-poverty and development efforts, and democracy itself. But by effectively preventing and countering corruption and demonstrating the advantages of transparent and accountable governance, we can secure a critical advantage for the United States and other democracies.”

President Biden has indicated that in issuing the National Security Study Memorandum, he is establishing countering corruption as a core United States national security interest. The Biden Administration has stated that it will “lead efforts to promote good governance; bring transparency to the United States and global financial systems; prevent and combat corruption at home and abroad; and make it increasingly difficult for corrupt actors to shield their activities.” President Biden has directed the Assistant to the President and National Security Advisor (in coordination with the Assistant to the President for Economic Policy and the Assistant to the President for Domestic Policy) to conduct an interagency review process to develop a strategy to significantly bolster the ability of the United States Government to:

  1. Modernize, increase, coordinate, resource, and otherwise improve the ability of key executive departments and agencies to promote good governance and prevent and combat corruption, including, as needed, by proposing relevant legislation to the Congress;
  2. Combat all forms of illicit finance in the United States and international financial systems, including by robustly implementing Federal law requiring United States companies to report their beneficial owner or owners to the Department of the Treasury; reducing offshore financial secrecy; improving information sharing; and, as necessary, identifying the need for new reforms;
  3. Hold accountable corrupt individuals, transnational criminal organizations, and their facilitators, including by, and where appropriate, identifying, freezing, and recovering stolen assets through increased information sharing and intelligence collection and analysis, criminal or civil enforcement actions, advisories, and sanctions or other authorities, and, where possible and appropriate, returning recovered assets for the benefit of the citizens harmed by corruption;
  4. Bolster the capacity of domestic and international institutions and multilateral bodies focused on establishing global anti-corruption norms, asset recovery, promoting financial transparency, encouraging open government, strengthening financial institutions’ frameworks to prevent corruption in development finance projects, and combating money laundering, illicit finance, and bribery, including, where possible, addressing the demand side of bribery;
  5. Support and strengthen the capacity of civil society, media, and other oversight and accountability actors to conduct research and analysis on corruption trends, advocate for preventative measures, investigate and uncover corruption, hold leaders accountable, and inform and support government accountability and reform efforts, and work to provide these actors a safe and open operating environment domestically and internationally;
  6. Work with international partners to counteract strategic corruption by foreign leaders, foreign state-owned or affiliated enterprises, transnational criminal organizations, and other foreign actors and their domestic collaborators, including, by closing loopholes exploited by these actors to interfere in democratic processes in the United States and abroad;
  7. Enhance efforts to quickly and flexibly increase United States and partner resources of investigative, financial, technical, political, and other assistance to foreign countries that exhibit the desire to reduce corruption;
  8. Assist and strengthen the capacity of domestic (including State and local) authorities and institutions, as well as partner and other foreign governments at all levels, to implement transparency, oversight, and accountability measures, which will counter corruption and provide their citizens with accessible and usable information regarding government programs, policies, and spending;
  9. Promote partnerships with the private sector and civil society to advocate for anti-corruption measures and take action to prevent corruption; and
  10. Establish best practices and enforcement mechanisms such that foreign assistance and security cooperation activities have built-in corruption prevention measures. 

The interagency review is to be completed within 200 days and the Assistant to the President and National Security Advisor are required to submit a report and recommendations to the President for further direction and action.