Biden Administration Releases United States Strategy on Countering Corruption

Biden Administration Releases United States Strategy on Countering Corruption

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On December 6, 2021, the Biden Administration released the United States Strategy on Countering Corruption (“Strategy”), the first of its kind. This Strategy reaffirms the Biden Administration’s focus on the fight against corruption and represents the culmination of an interagency review that began in June 2021, after President Biden issued a National Security Memorandum establishing the fight against corruption as a “core” national security interest. The ambitious Strategy calls for increased inter-agency and international coordination and information sharing with additional resources to be devoted to anti-corruption efforts, as well as the development of new guidance, strategy, and tools to improve the Administration’s goal of combatting corruption in the global economy. The release of the Strategy comes at a time of increased attention on anti-corruption and anti-money laundering (“AML”) enforcement with top officials at the Department of Justice (“DOJ” or “the Department”) making clear their intention to pursue harsher punishments and more robust international and domestic cooperation among foreign and domestic authorities. In light of this increased policy and enforcement attention, companies and financial institutions should take a fresh look at their existing compliance programs and consider improvements such as integrating their AML, sanctions, and anti-corruption functions to leverage information and proactively identify and manage risk.

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