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November 20, 2023

White Paper on Strengthening Coordination in Support of the "United States Strategy on Countering Corruption"

Executive Summary

In December 2021, the Biden-Harris Administration issued the United States Strategy on Countering Corruption (“Strategy”) calling upon the U.S. Government (USG) to elevate the fight against corruption as a core national security interest. The Strategy is based on the assessment that the global rise of corruption-fueled authoritarianism poses a threat to the international rules-based order and democracy itself. To protect and strengthen democracy, the United States must address globalized corruption as a systemic problem. The Strategy seeks to modernize American foreign policy to take the fight directly to authoritarian states and their proxies based on stronger legal and regulatory defenses at home.

This White Paper is intended to help support the USG modernization process required to achieve the national security objectives of the Strategy. The essence of the Strategy is to insist that U.S. departments and agencies will coordinate and synchronize delivery of anti-corruption policies, tools, and solutions. The execution of anti-corruption should be whole-of-government. No single actor in the USG, no one department or agency, can address the entire spectrum of risks, threats, and opportunities. While the Strategy repeatedly calls for departments and agencies to strengthen coordination, it does not provide specific guidance on how to make such change.

The White Paper is the product of the Interagency Roundtable Series on Strengthening Coordination to Counter Corruption Abroad – the New U.S. Strategy. The Roundtable Series was organized by the American Bar Association Rule of Law Initiative (ABA ROLI) as part of the Justice Sector Training Research and Coordination Plus Program (JusTRAC+) through a cooperative agreement with the State Department Bureau of International Narcotics and Law Enforcement. The Roundtable Series took place from April 19-22, 2022 and included leading officials from the National Security Council (NSC), State Department, USAID, Justice Department (DOJ), Treasury Department, Millennium Challenge Corporation (MCC), and Office of the Director of National Intelligence (ODNI). This November 2022 edition of the White Paper incorporates feedback and input provided by officials from State, USAID, DOJ and ODNI to the August 2022 edition.

The JusTRAC+ Roundtable Series demonstrated how leaders of USG departments and agencies are adapting, forging change, and innovating best practices in anti-corruption under the Strategy. Roundtable participants widely agreed that the Strategy does not call on America’s public servants simply to “do more” or “better” anti-corruption; it calls on them to “do the work differently”. The threat that authoritarian nations will use strategic corruption to destabilize nations and regions requires the USG to look over-the-horizon. Solutions to foreign and transnational corruption must be holistic. Democracies are vulnerable when they fail to govern; and such failure can be caused by local, transnational, and global factors. The USG should help democracies deliver good governance based on better institutions, rules, and norms; and galvanize new networks to champion transparency and act across borders to disrupt and defeat corrupt networks.

To help the USG execute the national security imperatives set by the Strategy, the White Paper organizes the participants’ recommendations and best practices into a new framework. The proposed framework is designed to help enhance collective ownership of the Strategy by responsible departments and agencies. It is built on seven desired interagency outcomes that include concerted and sustained action to conduct joint analysis, integrate tools and co-create innovative solutions to meet national security threats. It is intended help to foster a new discipline of national security and anti-corruption and instill collaboration as a norm across government. The seven processes should function iteratively to create collective will and capability not only to defend against, but to detect, prevent and pre-empt security threats of corruption. Below is a summary of the actions recommended under the framework: 

Desired interagency outcome 1, “Form a Common Operating Picture of Corruption”, is intended to help departments and agencies develop a common understanding of corruption as a national security threat in countries and theaters based on joint assessments using new diagnostic tools. This understanding will help form a common operating picture to prioritize and plan interventions. Departments/agencies should take four principal actions, as appropriate and as permitted by existing legal authorities, to achieve this outcome:

  1. Form a Common Operating Picture of Foreign and Transnational Corruption 
  2. Each Department and Agency Diagnoses Corruption Through Security Lens 
  3. Create New Diagnostics Based on Shared Tools, Evidence and Data 
  4. Incorporate Over-the-Horizon Analysis

Desired interagency outcome 2, “Expand Sharing of Intelligence, Information and Data on Corruption”, is intended to help departments and agencies share intelligence and data more efficiently, including by appropriately de-classifying intelligence; and increase interagency access to anti-corruption tools, expertise and know-how. Departments/agencies should take four principal actions, as appropriate and as permitted by existing legal authorities, to achieve this outcome:

  1. Expand Intelligence Sharing With Support from NSC/ODNI 
  2. Create an Online Database of “All Tools” for Fighting Corruption 
  3. Create a Database of “Who’s Who” in the USG Anti-Corruption Sector 
  4. Generate More State Department Reporting Cables on Corruption

Desired interagency outcome 3, “Lead Intra-Agency Processes to Elevate and Integrate Anti- Corruption”, is intended to support leadership of departments and agencies to elevate the fight against corruption as a core national security interest within all relevant policy-making and programming. To achieve this outcome, departments/agencies should assure that:

  1. New intra-agency bodies, including the CGAC, ACTF, Treasury Team, and the Commerce Task Force, have leadership and staff support, are fully resourced and have effective reporting lines to the Cabinet lead of their department or agency 
  2. New diagnostics are used to assess security threat of corruption in each policy area
  3. Intra-agency processes for integrating anti-corruption across sectors are implemented, resulting in removal of silos and “whole-of-department" action plans

Desired interagency outcome 4, “Form and Execute Holistic Solutions to Corruption”, is intended to help department and agencies develop solutions that maximize U.S. power, leverage, and impact by integrating all appropriate tools, including diplomacy, intelligence, trade and investment, law enforcement, anti-money laundering, sanctions, energy, foreign assistance and security assistance. Departments/agencies should take five principal actions to achieve this outcome:

  1. Create a Matrix for Prioritization and Sequencing 
  2. State CGAC/F, USAID ACTF Create Mechanism for Interagency to Help Design Foreign Assistance
  3. Pilot Interagency Innovation in at least two jurisdictions for Proof of Concept 
  4. Develop Agreed Criteria to Execute USAID and State/DOJ Rapid Response 
  5. Plan for Over-the-Horizon Threats

Desired interagency outcome 5, “Strengthen and Expand Linkages among Diplomacy, Foreign Assistance, and Other Tools”, is intended to ensure that diplomacy acts as a force multiplier for executing the Strategy by integrating anti-corruption with all U.S. foreign policy interests through bilateral diplomatic engagement, public diplomacy, and multilateral diplomacy. Departments/agencies should take seven principal actions to achieve this desired outcome:

  1. Prioritize and Mainstream Anti-Corruption in Diplomacy 
  2. Integrate All Appropriate Tools in Diplomacy 
  3. Apply Diplomacy to Lean-in Politically 
  4. Provide Guidance for Diplomacy in High-Risk Countries 
  5. Hone Public Messaging 
  6. Close Gaps Between Multilateral and Bilateral Diplomacy 
  7. Institute Anti-Corruption in Multi-Year Strategies

Desired interagency outcome 6, “Form Core USG Network to Help Disrupt and Defeat Corrupt Networks”, is intended to help form a “core USG network” of experts to galvanize foreign governments, multilateral institutions, and private sector and civil society actors to work across borders to disrupt and defeat networks of corrupt state and non-state actors. Departments/agencies should take five principal actions to achieve this desired outcome:

  1. Increase “trans-local” foreign assistance programming 
  2. Expand the Global Anti-Corruption Consortium 
  3. Leverage Key Multilateral Platforms, including the UNCAC Conference of State Parties, the International Anti-Corruption Conference and Summit for Democracy 
  4. Leverage Other Existing Multilateral Anti-Corruption Networks 
  5. Expand Multilateralization of Sanctions and Cooperation on Law Enforcement 

Desired interagency outcome 7, “Learn, Change and Innovate as a Community”, is intended to facilitate and capture new learning and innovation by the USG as a community of practitioners, including investing in the new discipline of anti-corruption and national security. Departments/ agencies should take three principal actions to achieve this desired outcome:

  1. State/CGAC, INL/KM, F, USAID/ACTF and DOJ join to create a process for sharing learning and data and providing trainings 
  2. Focus learnings and trainings on capturing and disseminating: a. Innovations occurring in the practice of anti-corruption in the field b. Data/evidence regarding the impact of programs delivered as interagency c. Know-how regarding skills/agility to out-maneuver corrupt networks
  3. Facilitate the learning and adoption of new best practices in support of interagency execution of Strategy 

The White Paper recommendations to the USG for executing the Strategy are intended to serve as a fulcrum for further deliberation and debate to help form wide consensus regarding goals, priority actions, and desired outcomes for interagency coordination.

View The White Paper