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Biden Administration Initiative on Foreign Corruption

The Biden Administration on June 3, 2021 released a memorandum on “Establishing the Fight Against Corruption as a Core United States National Security Interest.” The memorandum outlines that corruption threatens not only the United States’ national security but also economic equity, global anti-poverty and development efforts, and democracy itself. To address corruption concerns, the Biden Administration’s memorandum directs 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 review the interagency process under National Security Memorandum/NSM-2 and develop a Presidential strategy.

According to the Biden Administration’s memorandum, the Presidential strategy developed by key officials should aim to bolster the ability of the United States government to:

    • Improve the ability of key executive departments and agencies to promote good governance, prevent, and combat corruption
    • Combat all forms of illicit finance in the United States and international financial systems through implementing Federal law requiring U.S. companies to report their beneficial owners or owners to the U.S. Department of the Treasury
    • Hold accountable corrupt individuals, transnational criminal organizations, and their facilitators
    • Enhance the capacity of domestic and international institutions and multilateral bodies focused on establishing global anti-corruption norms, assets recovery, and improving the current financial infrastructure
    • Support the capacity of civil society, media, other oversight, and accountability actors to conduct research and analysis on corruption trends
    • Work with international partners to counteract strategic corruption by foreign actors
    • Strengthen efforts to increase resources for the United States and partners to reduce corruption
    • Enhance and assist domestic partners to implement transparency, oversight, and accountability measures to counter corruption
    • Promote and develop partnerships with the private sector and civil society to advocate for anti-corruption measures
    • Establish best practices and enforcement mechanisms for corruption

The interagency review process outlined in the Biden Administration’s memorandum on foreign corruption will be conducted within 200 days. The interagency review spans a wide reach of Federal agencies with different resources, perspectives, and focuses on corruption. It is yet to be determined how the Biden Administration will coordinate anti-corruption efforts in the future.

The CITI Program is aware of the ongoing and continuing impact of the Foreign Corrupt Practices Act, particularly at universities, remains a concern for U.S. federal officials and university administrators. The CITI Program Foreign Corrupt Practices Act (FCPA) course explores two of the Act’s main provisions – accounting transparency and bribery of foreign officials.

At the time of this blog post, it is yet to be determined the reach the interagency review could potentially have on activities at higher education institutions.

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