By Alma Angotti, Samantha Welch
On June 3, 2021, the Biden administration issued a National Security Study Memorandum1 that identifies acts of corruption as a threat to national security. In an effort to combat this growing problem, Biden has ordered an interagency review process that will lays the foundation for a new presidential strategy against corruption, to be completed by December 20, 2021.
According to the Memorandum, the fight against corruption is now considered a “core United States national security interest.” Fifteen different departments and agencies within the US Government (USG) responsible for economic and defense policy have been ordered to cooperate in a study of existing processes and recommend a new presidential strategy that will significantly enhance the USG’s ability to detect and prosecute individuals and entities engaged in corruption, both within the US and abroad.
In relation to the financial sector, the strategy will focus on the “demand side” of bribery, aligned with certain provisions of the Anti-Money Laundering Act of 2020 (AMLA), including Title LXIV, known as the Corporate Transparency Act (CTA).
The Memorandum highlights the intersection of AML and ABC efforts, both from the public sector and private sector. Both financial institutions and USG agencies will need to prepare for and analyze the new presidential strategy after it is published, by analyzing current processes and staffing in the areas highlighted by the Memorandum, and identifying those which may require enhancements.
Guidehouse has a team of AML and ABC experts that can help firms and agencies analyze and identify corruption exposure, including how such acts manifest throughout the financial system, and recommend steps or develop programs to help prevent and detect illicit finance related to corruption.
Special thanks to Andy Wright for contributing to this alert.
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