In the United States, systems of federal accountability and control are being steadily dismantled, including the loss of civil service protections and of long-held notions of government professionalism and checks on executive action. The extensive use of the pardon power, the gutting and politicization of parts of the Department of Justice and other enforcement agencies, along with the Supreme Court’s grant of broad immunity to the president, all provide impunity for powerful actors. At the same time, the president, his family, and close friends appear to be benefiting financially during his time in office, raising serious conflict of interest or undue influence concerns.
Many of these events seem to fall into a definition of state capture: large-scale corruption that distorts both the formulation and implementation of laws, norms, decrees, rules and regulations; provides impunity for powerful actors; and leads eventually to a reconfiguration of the state to serve certain powerful interests.
Much has been written on the United States’ democratic backsliding, illiberal regimes, and competitive authoritarianism, including comparisons with other countries. Yet far less attention has been paid to the related phenomenon of state capture: how leaders weaponize bureaucratic, law enforcement, and regulatory institutions to disable guardrails, evade accountability, enrich themselves and their allies, and reconfigure state institutions to perpetuate themselves in power and use the state for private gain.
This analysis examines the experiences of South Africa, El Salvador, Sri Lanka and Guatemala to illustrate how state capture took root in those countries and the lasting damage that unchecked corruption and self-dealing have inflicted on their institutions. Specifically, it looks to three aspects of state capture in those countries: the weakening of accountability and oversight mechanisms, the entrenching of impunity for the powerful, and the instrumentalizing of political power for personal and party gain.
Every case unfolds differently, and the trajectory of the United States will have its own pace and form, but the recurring patterns abroad offer a cautionary guide. By comparing, it may be possible to foresee – and maybe even prevent – future steps down the path to full-blown takeover of the state for the private, self-perpetuating interests of the president, his family, associates and friends.
State Capture: South Africa
Under President Jacob Zuma (2009-2018), South Africa became a notable (though little discussed) illustration of state capture. In 2018, Zuma was forced to resign, soon after the empaneling of a Judicial Commission of Inquiry into Allegations of State Capture (known as the Zondo Commission after its chair). The Commission held over 400 televised hearings and published a multi-volume report in 2022 detailing the nefarious efforts of the former president and his team to channel state funds to himself, his family and his cronies. The Commission’s Report found that Zuma allowed the Guptas, a family of Indian-origin businessmen, to steal billions from the state, including through shady contracts and kickbacks schemes involving the mining, energy, transportation, agriculture and communications sectors.
Weakening of Accountability and Oversight Mechanisms
The Commission found that Zuma and the Guptas were able to implement the takeover of state institutions for their own ends. The Guptas were able to install their own loyalists and influence the hiring and firing of state personnel. For example, former Minerals Minister Adv. Ngoako Ramatlhodi was removed for refusing to cooperate with the Guptas and replaced by Mosebenzi Zwane, whose appointment the Guptas had specifically sought. The heads of all three intelligence agencies were fired and replaced. With allies in place, the Guptas and the Zuma family obtained lucrative state contracts but did no work, created kickback schemes, and used state resources like military airports or the national airline as their private assets.
The Zondo Commission Report found that the Zuma government sidelined, attacked, and fired state auditors and civil servants and imposed often-unqualified loyalists instead. Zuma’s government privatized auditing of state-related accounts and procurement contracts to international auditing firms that never seemed to find any graft. In particular, the Commission found that the South African Revenue Service (SARS) had been systematically dismantled. Its report found that over 2000 experienced personnel were fired or pressured into quitting by a “culture of fear and bullying,” and that its investigative and auditing functions were taken over by unqualified but politically compliant staff in the name of restructuring and dismantling a (nonexistent) rogue unit. The Tax Commissioner was handpicked despite his lack of qualifications and without following the regulations of the South African Revenue Act, and worked with consultants Bain & Company and Zuma to dismantle crucial parts of SARS, such as the Projects and Evidence Management and Technical Support Division, which severely undermined the tax authority’s ability to combat illicit economic activity.
Impunity
Under Zuma, prosecutorial and police functions were weakened to produce impunity for the looting. The number of prosecutors decreased by 22%, with steeper losses in anti-corruption units. The National Director of Public Prosecutions was pressured and then received a “golden handshake” to resign, anti-corruption prosecutors found themselves the subject of spurious charges and investigations; and the new chief prosecutor refused to investigate anyone near Zuma. Anti-corruption activists were prosecuted, while serious corruption cases were delayed or dismissed. The FBI equivalent (known as the Hawks) was placed under direct executive branch control despite Constitutional Court rulings requiring it to be independent; all four of its directors under Zuma were later charged with fraud and corruption. Public Protector Thuli Madonsela, a constitutionally mandated anti-corruption watchdog looking into Zuma’s corruption, became the subject of an unfounded intelligence ministry probe. Judges who questioned Zuma’s actions were attacked in the media as representatives of a “judicial dictatorship,” while Zuma ignored decisions of the Constitutional Court on using tax revenue for personal expenses.
Enrichment
The consequences of the unchecked graft and the corruption have been felt throughout South Africa until today. The country lost between US$3 and $17 billion and GDP shrunk by 4% a year. Most of that money will never be recovered since the Guptas have fled to the UAE and apparently will not be extradited. Trust in the ANC-led government was shaken, and public services like the national airline, electricity and transportation were devastated and pushed to near-bankruptcy, with long-lasting effects including blackouts and service cuts that persist. Zuma and his accomplices face multiple (albeit slow and incomplete) investigations and prosecutions as a result of the Commission’s findings, and some stronger anti-corruption laws have been passed, but many of the Zondo Commission’s recommendations are still pending. Bain & Company was barred from doing business in the country for ten years.
State Capture: El Salvador
Nayib Bukele was elected in 2019 on an anti-crime platform, backed by a small right-wing political party. He spent the next two years building up his own party, New Ideas, and in the 2021 legislative elections won an overwhelming majority in the legislature. With no meaningful legislative checks, he began a process of institutional dismantling and repurposing to his agenda.
Weakening of Accountability and Oversight Mechanisms
Bukele began by putting his people into those parts of government that were supposed to be independent. The constitutionally independent Court of Accounts (public auditor), the Electoral Tribunal and the Human Rights Ombudsman’s office were filled with party loyalists. Civil servants who protested budget cuts to education and health were fired.
A “state of exception” has now been in place for over three years, reapproved by Congress with no debate every thirty days, thus creating a permanent emergency that broadens discretion and removes accountability. The state of exception, as detailed here, limits access to an attorney, weakens due process, and has resulted in some 85,000 people held indefinitely under harsh conditions, with over 430 deaths in custody. There is no judicial oversight or public data available on anything related to the state of emergency.
Impunity
Once he had a congressional majority, Bukele quickly replaced an independent prosecutor with a loyal one, who dissolved anti-corruption units and closed down investigations into Covid-era corruption and negotiations with gang leaders. The legislature in 2021 granted retroactive immunity for any irregularities arising from pandemic-related spending. Despite campaign promises of support, Bukele soon terminated an anti-corruption commission backed by the Organization for American States.
The Bukele-controlled legislature quickly also attacked the judiciary, removing the entire Constitutional Chamber of the Supreme Court and replacing it with new judges; they soon authorized Bukele’s indefinite reelection despite a constitutional prohibition, and refused to take up cases arising from the state of emergency. His civil service “reform” effort removed the country’s few independent judges under the pretext of imposing (arbitrary) age limits.
Enrichment
The U.S. government in 2021 sanctioned three Bukele ministers/advisors for corruption in COVID-19-related contracting and negotiating with gangs for votes. There have been persistent reports of widespread corruption in the prison system, with prison officials at all levels extorting the families of detainees. Bukele, his brother/advisors and family have recently bought 361 hectares of land, and a company under their control went from $14,000 in capital to over $6 million from 2021 to 2023. It has been difficult to pursue information about their financial dealings because of a crackdown on information access. A 2023 law on public contracting removed from public scrutiny contracts designated as “strategic” by the presidency as well as municipal spending. Information on spending and loans for building new prisons (like the infamous CECOT) is also classified along with security plans and policies, the declared assets of the president and the finances of several government funds, including one dedicated to bitcoin. The asset declarations of public officials, required to compare asset levels before and after public service, are now classified.
As a result of these changes, there are few limits on Bukele and his party. El Salvador today faces increased authoritarianism, including imprisonment and exile of journalists and anti-corruption activists, widespread extortion and abuse related to mass imprisonment, and a climate of fear in poor neighborhoods.
State Capture: Sri Lanka
The Rajapaksa family dominated Sri Lanka’s politics from 2005 to 2022 (with a brief pause from 2015-2019). Its reign only ended when economic collapse and massive popular demonstrations forced the family from power.
Weakening of Accountability and Oversight Mechanisms
The Rajapaksas came to power after brutally defeating an armed insurgency in the north and east of the country. They promptly centralized power, culminating in 2020 with the 20th amendment to the Constitution. This amendment changed government from a parliamentary system to one concentrated in the executive branch, giving the president broad immunity, the ability to hold ministries, appoint and remove ministers, dissolve Parliament after a shorter period, and control appointments to independent commissions—including those for elections, public service, police, and anti-bribery. The (anti-) Bribery Commission lost the ability to initiate investigations, and the reform abolished the national procurement commission and the audit service commission.
Impunity
Attacks on the independence of the judiciary were common during the Rajapaksa period. Then-chief justice Shirani Bandaranayake was impeached and removed from office in 2013 despite a prohibition from the Supreme Court and replaced by a Rajapaksa ally. Mobs and media campaigns attacked judges. The 2020 constitutional amendment gave the president the right to name the top levels of the judiciary, And in 2021, the prime minister attempted to stop ongoing trials against high-ranking officials accused of serious human rights violations, as well as family members of the President and Prime Minister facing corruption charges. Killings, enforced disappearances and other rights violations arising from the destruction of the Tamil insurgency continue largely uninvestigated.
Enrichment
At one point more than 40 family members served in key government positions, controlling a quarter (by some estimates three quarters) of the budget. They steered huge infrastructure contracts, often obtained through onerous loans, to their hometown, their family and friends. At the same time, they amassed great wealth. Estimates of the money they stole during their time in office range from $5.3 up to $7 billion, including properties in London and Dubai, a network of shell companies and offshore trusts.
They slashed taxes, expanded corporate tax exemptions and made other disastrous and uninformed economic decisions, leading to the meltdown of the economy. That meltdown caused widespread suffering, More than a million Sri Lankans lost their jobs and a million households lost access to electricity. Over four million people were pushed below the national poverty line.
State Capture: Guatemala
Until 2023, Guatemala followed some of the patterns described above, except that those in charge were not a single strongman or family but a group of state officials and private elites aligned with sectors of the military and of organized crime, popularly known as the “pact of the corrupt.” The election of Bernardo Arévalo as president on an anti-corruption campaign has led to some positive changes since 2023, but also shows the limits of changing the president while the underlying structures of state capture remain intact.
Weakening of Accountability and Oversight Mechanisms
Guatemala under three successive presidents (2011-2023) saw the partial or total dismantling of even the weak safeguards in place. The Human Rights Ombudsman was threatened and eventually forced to leave the country, while the head of the Tax Agency, Juan Francisco Solórzano Foppa, was fired and then jailed for “ideological falsity.” The national university and the ad-hoc committees in charge of judicial selection were taken over by forces aligned with the “pact.” Journalists like José Zamora who investigated corruption were jailed on spurious charges. The most important efforts to weaken accountability and entrench impunity concerned the justice system.
Impunity
Created in 2006 through a U.N.-Guatemala agreement, Guatemala’s International Commission against Impunity (CICIG)’s hybrid structure—international investigators working with national prosecutors—was designed to prosecute shady organized-crime networks that had captured the state. Over a decade, the commission and its Guatemalan partners helped convict hundreds of officials, including two presidents and numerous ministers, and drove major legislative reforms. The Commission closed in 2019 after then-president Morales refused to renew its mandate. Meanwhile, Morales appointed Consuelo Porras as Attorney General.
Porras, whom the United States later sanctioned for corruption, began closing investigations, declining to revoke the immunity of allegedly corrupt judges and dropping cases. Porras redirected the office away from prosecuting large-scale corruption cases and into political vengeance against perceived enemies. Prosecutors themselves, along with judges and administrators connected to CICIG, were prosecuted for doing their jobs, on spurious charges including unauthorized removal of documents (that were in danger of being destroyed) or (unspecified) abuse of authority. Many had to flee the country, and several spent years in jail.
Enrichment
Ex-Presidents Portillo and Perez Molina were convicted for money laundering or embezzlement, while ex-President Morales was accused of illegal campaign finance but never prosecuted, and ex-President Giammattei and his secretary were sanctioned by the United States for receiving bribes, including from Russian mining interests.
Since 2023, however, prosecutions target President Arévalo, his political party, and students and indigenous leaders who defended his electoral victory. It has proven impossible for Arévalo to oust Porras, her deputies, or the judges aligned with her, or to stop her harassment. As a result, Arévalo has been stymied in his attempts to clean up the corruption and improve public services, and public frustration continues to grow. Porras’ term, along with that of the Constitutional Court, ends in 2026. The “pact of the corrupt” is expected to fight any efforts to install a less pliant figure as Attorney General.
Similarities to the United States
Weakening of Accountability and Oversight Mechanisms
In the United States, we see many of the same worrisome signs. The civil service has come under political pressure, with experts replaced or reassigned for perceived disloyalty or random cost-cutting and increased numbers of political appointees. Offices focused on fraud, self-dealing, and conflicts of interest—such as inspector generals, consumer protection, whistleblowers, and ethics counsel—have been hollowed out or sidelined. Roughly a quarter of the investigations staff within the Internal Revenue Service and almost a third of tax auditors have left or been removed; by 2027 half the enforcement budget will be gone. Enforcement aimed at tax shelters used by the very rich has been dismantled, and longtime employees who worked on reining in the shelters removed.
The administration has also increasingly relied on “acting” officials and ad hoc advisers—family members, business associates, or donors—to bypass normal vetting and confirmation processes. Businesspeople like Elon Musk have been placed in informal roles, such as the head of the nebulous DOGE entity, without statutory authority or oversight. Such maneuvers may appear bureaucratic, but they erode transparency and public trust in equal enforcement of the law—which is precisely the point.
Impunity
As widely noted, the Department of Justice and the FBI have been politicized, with prosecutors hired and fired based on their charging decisions or perceived loyalties. Experienced officials have moved to unfamiliar posts both to encourage them to leave and to undermine the efficiency of accountability mechanisms, as when FBI and DOJ agents were moved from investigating public corruption to immigration beats. Department of Justice’s Public Integrity Section reportedly saw its staff fall from 30 to five attorneys.
Inconvenient investigations, such as those into ICE Commissioner Thomas Homan’s apparent receipt of a $50,000 bribe, have been shelved, and tax audits of friends halted or dismissed, while the government threatens audits and even to deny tax-exempt status to perceived enemies.
Enrichment
Examples of the enrichment of family, friends and ideological allies of the president abound, and have been detailed here, here and here, among others. In short, through the pardon power, executive orders and regulatory efforts (especially around crypto policy), various pay-to-play initiatives, increasing opacity and secrecy, and complex deals with foreign powers, the United States is edging closer to the kind of captured state it has long advised other countries to combat.
* * *
If state capture is a process, not an event, the United States still has time to halt its advance. The patterns are visible: the hollowing out of oversight, the politicization of investigative and prosecutorial functions, and the reshaping of public authority for private enrichment. Perhaps the lesson is that a descent into authoritarianism and rights violations goes hand in hand with the capture of the state for the financial as well as political gain of those in power. That was the case in South Africa under Zuma, in Guatemala under pre-2023 governments, and in Sri Lanka under the Rajapaksas; it is still the case with Bukele in El Salvador, as well as elsewhere.
Once control over bureaucracy, prosecution, and revenue is secured, recovery becomes far harder. Recognizing the warning signs now is not alarmist; it is the first act of prevention.
