Halfway through the first-ever United Nations General Assembly Special Session on corruption, the White House announced a new initiative: a comprehensive national security strategy to combat corruption. A memo from President Biden specifically named partnership with the private sector as a core tenet.
Messages from the Treasury, the DOJ, USAID, and the State Department echoed the sentiment throughout the week, with officials pledging to strengthen the FCPA and prioritize prevention, enforcement, and policy. And in a rare celestial alignment, Congress stands united with the executive branch, with several meaningful anti-corruption bills under consideration and the establishment of the bipartisan Counter-Kleptocracy Caucus.
The U.S. government hasn’t been this united on an issue since the fight against terrorism in the early 2000s. So what does this mean for the private sector?
Countering corruption as a comprehensive, whole-of-government priority, executive agencies and Congress are likely to be unified in holding multinational companies to higher ethical standards through policy and accountability. This effort will gain momentum with an influx of resources, staffing, and budget for legal enforcement agencies—presumably leading to more enforcement.
The White House memo also names multilateralism as a priority, which will contribute to continued coordination with allies on anti-bribery enforcement, along with capacity-building partnerships with governments around the world. It’s also possible that U.S. allies such as Canada, the EU, and the UK will follow suit with similar strategies to counter corruption, leaving corrupt actors and kleptocrats with fewer places to hide their dirty money.
Companies should respond by revisiting and updating their compliance programs and ensuring adequate budget, staffing, and resources. After a tumultuous 18 months and especially in combination with this announcement, it would be prudent for compliance officers to conduct a transitional risk assessment—even in abridged form—and ensure that compliance resources are commensurate with its sales marketing trajectory. And for compliance officers making a case for more resources, the White House memo is an excellent starting point.
While there is a lot of work to do, the whole-of-government mobilization against corruption appears to mark a fundamental change for the United States. If successful, the strategy will create fairer, more transparent markets for multinational companies, prevent the theft of national resources, support sustainable development, and bolster democracy globally. As the White House memo explicitly states, the private sector has an enormous role in preventing corruption from happening in the first place, and all signs point to robust anti-bribery enforcement, increased accountability, and high expectations for multinational companies’ compliance programs.