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Compliance officers take note: White House affirms anti-graft priorities

President Barack Obama issued a National Security Strategy Friday, the first one since 2010 and only the second from his administration.

The NSS is important. It sets the agenda for the executive branch of the government -- the DOJ and SEC, the State Department, the Commerce Department, the Treasury Department, and so on -- and it signals foreign policy priorities to Congress.

A key goal of the 2015 National Security Strategy is for the United States to continue "leading the way" in the global fight against graft. Why? Because graft, as the NSS repeatedly says, is a direct threat to peace, the rule of law, human rights, democratic institutions, and even public health.

For compliance professionals, the 2015 NSS is a clear signal to expect robust enforcement of America's main anti-graft tools. Those include the Foreign Corrupt Practices Act, used to prosecute bribe payers, and Presidential Proclamation 7750, used to impose secret visa bans on bribe-taking foreign officials and their families and friends.

There's also the Kleptocracy Asset Recovery Initiative. It's a DOJ-led program that started in 2011. The initiative targets crooked overseas rulers and their cronies. It relies on anti-money laundering laws, wire and mail fraud statutes, and criminal and civil forfeiture actions.

The 2010 version of the NSS made an historic leap. It said "pervasive corruption is a violation of basic human rights and a severe impediment to development and global security." That was the first time any U.S. administration publicly linked graft and human rights.

Five years on, the 2015 version of the National Security Strategy is more practical about corruption. Here's the central statement about it:

The corrosive effects of corruption must be overcome. While information sharing allows us to identify corrupt officials more easily, globalization has also made it easier for corrupt officials to hide the proceeds of corruption abroad, increasing the need for strong and consistent implementation of the international standards on combating illicit finance. The United States is leading the way in promoting adherence to standards of accountable and transparent governance, including through initiatives like the Open Government Partnership. We will utilize a broad range of tools to recover assets stolen by corrupt officials and make it harder for criminals to hide, launder, and benefit from illegal proceeds. Our leadership toward governance that is more open, responsible, and accountable makes clear that democracy can deliver better government and development for ordinary people.

*     *     *

Last year, we talked about the link between corruption and the spread of the ebola virus. Some readers didn't like that idea or believe it.

But the White House Friday acknowledged in the NSS the link between corruption and public health crises. And it talked about how each can damage civil society and threaten stability and security.

Corruption is endemic and public health systems are broken in too many places. And too many governments are responding to the expansion of civil society and free press by passing laws and adopting policies that erode that progress. Ongoing conflicts in Sudan, South Sudan, the Democratic Republic of the Congo, and the Central African Republic, as well as violent extremists fighting governments in Somalia, Nigeria, and across the Sahel all pose threats to innocent civilians, regional stability, and our national security.


The 2015 National Security Strategy is here (pdf).


Richard L. Cassin is the publisher and editor of the FCPA Blog. He can be contacted here.