By: Karl H. Buch, Gray Stratton, John M. Hillebrecht, Jonathan D. King, Courtney Gilligan Saleski, Aurelie Ercoli, and Sarah Walsh.
On December 6, 2021, the Biden-Harris Administration issued a memorandum outlining the first-ever United States (US) Strategy on Countering Corruption (the Strategy).[1] The Strategy comes on the heels of President Biden’s announcement earlier this year that the fight against corruption is a core US national security interest and the related memorandum that directed an inter-agency review process aimed at developing an anti-corruption strategy within 200 days, which DLA Piper summarized in a prior alert.[2]
The Strategy is the result of this inter-agency review process and sets forth a comprehensive approach for the US to work domestically and internationally with various partners “to prevent, limit, and respond to corruption and related crimes,” with a “particular emphasis” on the transnational elements of corruption.[3] This approach is in recognition of an evolving understanding of “corruption’s strategic impact and the increasing interconnectedness of the global economy.”