HSE University Anti-Corruption Portal
The United States Releases a Plan on How to Implement the Anti-Corruption Strategy
Natalia Gorbacheva, Vladislava Ozhereleva

The United States Strategy on Countering Corruption, hereinafter referred to as the Strategy, was released back in December 2021. Last September, the U.S. Department of State (Department) published its implementation plan containing tasks spanning over the period between 2023 and 2025 designed to achieve the main objectives of the Strategy.

1. Modernizing, Coordinating, and Resourcing Efforts to Fight Corruption

1.1. Enhance corruption-related research, data collection, and analysis:

  • Collect data on the implementation of the Strategy, in particular, by drafting action plans and ensuring interagency cooperation on the issue, improve the methods of data collection and analysis on corruption offences and their usage by public bodies;
  • Provide U.S. Embassies with guidance on corruption analysis, diagnosis, and data usage on corruption offences;
  • Disseminate and apply findings on topics such as anti-corruption campaigns, asset recovery, and how police can best contribute to combating high-level corruption.
  • Continue to produce annual reports which provide country-specific data on corruption issues, including on human rights practices, the international narcotics control etc.

1.2. Improve information sharing with the U.S. government, with non-U.S. Government entities, and internationally:

  • Empower all Department officers to prioritize anti-corruption into relevant diplomatic engagements also by developing an anti-corruption messaging toolkit, holding anti-corruption awareness-raising initiatives, organising anti-corruption training etc.;
  • Curate existing anti-corruption data, analysis, technical tools, and lessons learned in platforms accessible to the Department and where possible, the interagency (such as the regularly updated portal of the Fiscal Transparency Innovation Fund (FTIF) projects, a unit of the Department responsible for the allocation of foreign financial aid);
  • Continue monthly meetings of an Anti-Corruption Working Group to facilitate information-sharing among Department staff, the interagency, and other stakeholders;
  • Provide regular updates to Congress on success stories, jurisdictions of concern, and country implementation of international and regional anti-corruption standards;
  • Strengthen the Department’s anti-corruption public communications approach by utilizing relevant social media accounts, updating relevant webpages of the Department’s website, conducting non-governmental partner consultations.

1.3. Increase focus on the transnational dimensions of corruption:

  • Expand research on kleptocracy, train civic activists to safely investigate and publicize kleptocratic links for audiences;
  • Build law enforcement and criminal justice sector investigative and prosecutorial abilities to continue combating transnational organized crime and corruption, engage competent authorities in identifying trends regarding corruption-facilitated illicit finance;
  • Target programming to address corruption as a transnational issue, including through Summit for Democracy deliverables such as the Democracies Against Safe Havens initiative and associated projects.

1.4. Organize and resource the fight against corruption, at home and abroad:

  • Develop common framework for anti-corruption efforts within the Department and map comparative advantages for resource allocation;
  • Scale up team supporting the Coordinator on Global Anti-Corruption, the post established in 2021, to facilitate greater coordination, engagement, and integration of corruption issues within U.S. foreign policy;
  • Facilitate senior Department leadership participation in Anti-Corruption Policy Board responsible for defining anti-corruption priorities of the U.S. foreign policy to discuss cross-cutting anti-corruption issues;
  • Undertake internal messaging and capacity building to improve process of reporting anti-corruption spending;
  • Partner with the interagency to develop an integrated, strategic approach that will guide the best use of U.S. resources toward anti-corruption goals.

1.5. Integrate an anti-corruption focus into regional, thematic, and sectoral priorities:

  • Identify and maintain a list of anti-corruption points of contact at each U.S. embassy;
  • Create a centralized resource for country-based anti-corruption tools and strategies;
  • Integrate anti-corruption considerations into other foreign policy issues, such as on conflict prevention, illicit finance foreign assistance programming, counter-wildlife trafficking etc., and integrate anti-corruption efforts with equity efforts, including promoting gender equity and equality and other efforts to support marginalized populations etc.;
  • Integrate anti-corruption considerations into drafting, reviews, and updating of comprehensive and other strategies;
  • Leverage technical guidance to build the capacity of relevant stakeholders to implement effective anti-corruption systems based on international standards and to meet the objectives of global programs for infrastructure investment.

2. Curbing Illicit Finance

2.1. Address deficiencies in the U.S. anti-money laundering regime:

  • Regularly participate in an interagency discussion on digital assets with Departments of Treasury, Justice, Commerce, and the U.S. Agency for International Development (USAID).

2.2. Work with partners and allies to address deficiencies:

  • Support law enforcement networks to further coordinate and share practices on corruption investigations and cases, build capacity of criminal justice actors to improve weak institutions in order to counter corruption and related crimes;
  • Undertake additional efforts to address the enablers of corruption, for example, consider the risks and threats posed by gatekeepers and enablers of corruption schemes;
  • Through funding technical assistance by the Federal Bureau of Investigation and other competent entities, support local authorities to investigate corruption and other related offences;
  • Review transparency in government natural resource contracts and licensing in annual and fund projects to support extractive transparency;
  • Support partner governments in recovering and returning assets;
  • Facilitate national risk assessments on legal persons/arrangements, develop country-specific beneficial ownership country guides for jurisdictions with beneficial ownership weaknesses, and deliver technical assistance to address compliance with Financial Action Task Force (FATF) recommendations;
  • Identify critical illicit finance deficiencies, such as by reviewing FATF Mutual Evaluation findings and identifying strategies to address such deficiencies;
  • Help investigators develop skills such as bitcoin tracing and online fraud investigations as a part of wider financial investigations and efforts to proactively disrupt illicit finance flows.

3. Holding Corrupt Actors Accountable

3.1. Enhance enforcement efforts:

  • Support efforts of partnering countries to counter foreign bribery and money laundering of corrupt proceeds as well as efforts to enhance asset recovery related to such conduct.

3.2. Update tools available to promote the accountability of corrupt actors at home and abroad:

3.3. Work with partner countries to bolster anti-corruption enforcement and amplify use of tools:

  • Strengthen the use of anti-corruption sanctions;
  • Cooperate with civil society organisations;
  • Engage key international partners through the Democracies Against Safe Havens initiative and similar programs to assist in the development of sanctions and visa restriction actions for specific countries;
  • Under the Democracies Against Safe Havens initiative, fund programs to enhance Financial Intelligence Unit (FIU) investigations and operations and educate vulnerable jurisdictions about financial crime including money laundering;
  • Promote implementation of the OECD Recommendation on foreign bribery and engage actively in the OECD Working Group on Bribery.

3.4. Strengthen the ability of foreign partner governments to pursue accountability:

  • Expand funding for rule of law programs (such as Department of Justice’s Resident Legal Advisors) and anti-corruption and justice reforms in law enforcement and justice authorities;
  • Place advisors (e.g., FBI LEGATs, Judicial Attachés, or Resident Legal Advisors) at U.S. embassies in order to enhance counterpart capabilities to effectively investigate, prosecute, and adjudicate complex, transnational and national anti-corruption cases;
  • Through the International Law Enforcement Academy, offer courses on anti-corruption to train criminal justice sector professionals from partner countries around the world at academies in Accra, Bangkok, Budapest, Gaborone, and San Salvador, as well as an executive-level academy in Roswell;
  • Support information exchange through the OECD Working Group on Bribery Law Enforcement Officials, Asset Recovery Interagency Networks, the Egmont Group, INTERPOL, and others.

3.5. Bolster the ability of civil society, media, and private sector actors to safely detect and expose corruption, increase public awareness, and pursue accountability:

  • Increase the visibility of government procurement through the consolidation of government procurement information;
  • Build capacity of civil society to participate in the budget formulation process, monitor public expenditures, and hold government officials accountable; increase capacity of civil society to investigate and report on corruption and promote accountability through technical capacity building and information sharing between civil society organizations; support civil society organization capacity building projects in South and Central Asia through the Democracy Commission Small Grants Program;
  • Support OECD in organizing a Business Integrity Roundtable;
  • Assign the annual Anti-Corruption Champions Awards;
  • Support investigative journalists also through training;
  • Engage private sector partners on anti-corruption efforts;
  • Support study tours for government officials on anti-corruption-related topics, such as investigative journalism, rule of law, government transparency, and media freedom;
  • Support the Civil Society Anti-Impunity Complaint Platform etc.

4. Preserving and Strengthening the Multilateral Anti-Corruption Architecture

4.1. Bolster existing anti-corruption frameworks and institutions:

4.2. Redouble efforts at multilateral fora:

  • Continue to support the Open Government Partnership (OGP) and ensure U.S. leadership in OGP;
  • Support implementation of Summit for Democracy commitments including through the Summit for Democracy Financial Transparency and Integrity Cohort, and leverage the Summit for Democracy platform to continue to rally the international community on anti-corruption;
  • Conduct follow-up on the Inter-American Action Plan on Democratic Governance, and on due-outs from the 20th International Anti-Corruption Conference;
  • Chair the Asia-Pacific Economic Cooperation (APEC) Anti-Corruption and Transparency Experts Working Group and host the 10th session of the UNCAC Conference of the States Parties in 2023;
  • Engage with international financial institutions (IFIs) on efforts to align and strengthen anti-corruption guardrails, oversight of procurement, and integration of anti-corruption into IFI programming;
  • Continue to support multilateral initiatives that promote international principles of transparency, integrity, and accountability.

5. Improving Diplomatic Engagement and Leveraging Foreign Assistance Resources to Advance Policy Goals

5.1. Elevate and expand the scale of diplomatic engagement and foreign assistance to address corruption:

  • Determine list of countries of interest for U.S. engagement;
  • Establish new coordination mechanisms to ensure interagency input in the design of foreign assistance, as needed;
  • Provide guidance for diplomatic engagement to address corruption in high-risk countries and track opportunities for such engagement.

5.2. Protect anti-corruption actors:

  • Detect existing gaps to identify necessary changes in the approach to better protect whistleblowers;
  • Engage with NGOs who have been threatened about existing global emergency assistance mechanisms, such as the Lifeline: Embattled CSOs Assistance Fund;
  • Protect whistleblowers and media through short and medium protection programs.

5.3. Leveraging innovation in the fight against corruption:

  • Through the Global Innovation through Science and Technology (GIST) initiative, the Anti-corruption Solutions through Emerging Technologies and the TechCamp Program, empower innovators to develop startup solutions that address economic and corruption challenges;
  • Engage with the private sector on how corrupt actors are evolving in response to new technologies, and what adjustments are needed to address corruption;
  • Facilitate the deployment of government anti-corruption experts to help address emerging corruption challenges in the justice sector in countries where there is an opening for reform and political will;
  • Explore ways to expand engagement on anti-corruption at the sub-national level.

5.4. Improve coordination and risk analysis across foreign assistance:

  • Facilitate pilot programs for interagency coordination on country-specific anti-corruption efforts.
  • Increase foreign assistance accountability, coordination, and risk analysis;
  • Conduct additional national or sub-national corruption assessments and implement reviews to ensure recipient countries meet anti-corruption standards.

5.5. Improve security assistance and integrate corruption considerations into military planning, analysis, and operations:

  • Develop protocols for the Department to assess corruption risks in its security cooperation and assistance activities, as well as partners’ political will for anti-corruption reform; develop guidance for the Department for applying risk assessment findings and Security Sector Governance analysis, as well as mitigation strategies.
  • Help partners develop systems that reduce the likelihood of corruption by enhancing oversight, accountability, and transparency.
Corruption whistleblowers
Political context
Illicit enrichment
Asset recovery
Civil society
International cooperation
Foreign bribery
Criminal prosecution

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