The United States has long evaluated other governments’ efforts on a wide range of important issues. Yet Congress has directed the executive branch to judge others on a new front — curbing corruption — at a moment when the Trump administration is weakening many of the country’s anti-corruption safeguards and its credibility on these issues is increasingly in question. That tension matters acutely: this month, the State Department must issue its first-ever assessments of foreign anti-corruption efforts required under the recently enacted Combating Global Corruption Act. The forthcoming rollout will test whether the United States can still offer clear-eyed evaluations of anti-corruption efforts abroad at a moment when its own safeguards are eroding.
U.S. Global Evaluations Expand to Anti-Corruption Efforts Abroad
Per legislative mandates, the U.S. State Department reports publicly and to Congress on how foreign governments meet international and U.S. standards on a range of issues, such as human rights, trafficking in persons, and investment climate. These assessments inform government decision-making, business investments, academic research, and civil society advocacy.
In August, the Trump administration released its first installment of the annual human rights reports, a State Department publication that has been produced for decades. The release was widely criticized for a lack of candor about certain allied countries (including El Salvador and Hungary), the omission of key issues (such as discrimination), and the unwillingness of senior leadership to promote the reports. That precedent now casts a long shadow over the forthcoming first-ever iteration of annual reports the State Department is required to produce under the recently enacted Combating Global Corruption Act.
The Act, passed in 2023, requires the State Department to report annually to Congress and the public on foreign government efforts to counter corruption, beginning this month. While the Act has not received much public attention, it has the potential to help promote progress and check backsliding on an issue that regularly harms American interests globally.
Yet, as this Just Security series has shown, the United States is facing a moment when its credibility in countering corruption — and weighing in on the efforts of others — is under strain. In its foreign and domestic policies, the Trump administration has undermined or terminated a wide range of U.S. anti-corruption initiatives. This comes on top of a longer history of bipartisan concern about influence peddling and the extensive role of money in U.S. politics, among other issues.
Beyond the general issue of U.S. credibility, two challenges warrant particular attention. First, the integrity of the reports could be tainted by political interference or inadequate department resourcing. Second, the Act’s potential will be undermined if the reports are not followed by corresponding policy actions like appropriate sanctions or training for U.S. officials.
Nonetheless, Congress and civil society should embrace the Act as a framework and a tool among many for reviewing the state of anti-corruption efforts globally, critically evaluating the U.S. government’s own adherence to the Act’s standards, and supporting those who are calling for reform.
A Potentially Impactful Reporting Scheme
Prior to 2025, the United States had recently taken modest but meaningful steps to counter corruption at home and globally. It often did so with strong bipartisan support, based on the understanding that fighting corruption would pay dividends for national security, economic prosperity, and human rights. Recent high-profile initiatives included implementation of the Global Magnitsky Act and Corporate Transparency Act, ethics pledges by executive branch officials, and the creation and execution of the U.S. Strategy on Countering Corruption.
The Combating Global Corruption Act aimed at building on this progress. The bill was a top priority for then-Senator Ben Cardin, who secured the Biden administration’s support as one of his first acts when he became chairman of the Senate Foreign Relations Committee in September 2023. This was a fitting choice, since it was a federal indictment for bribery and other corrupt acts that drove Cardin’s predecessor out of that chairmanship. After receiving unanimous support in committee – including from then-Senator Marco Rubio – and the full Senate, Cardin’s legislation became law in December 2023.
The Act’s main feature is to require the State Department, by December 22 and for seven years thereafter, to assess and report to Congress and the public regarding foreign governments that are “sustaining or making good progress on anti-corruption efforts.” The State Department must also provide a classified report to Congress on foreign governments “making limited to no effort…and no meaningful progress on combating corruption.” These assessments are to be based on a list of standards and criteria rooted in historical U.S. anti-corruption approaches and international treaties that the United States has ratified. The standards focus on criminalization of corruption, enforcement of the law, and prevention efforts.
In an earlier draft form, the Act was modeled on the State Department’s annual country reports on trafficking in persons (TIP), which publicly rank all countries in three tiers based on the extent of each government’s efforts to eliminate trafficking. By many accounts, the public stigma of a negative TIP ranking or the threat of one have been impactful in spurring foreign governments into improving their record. These reports have also included a self-assessment of the U.S. government’s record.
As enacted, the Combating Global Corruption Act does not require a ranking of all countries, nor the publication of any critical assessments. Still, the Act provides an opportunity for the State Department to highlight which foreign governments are sustaining or making steps in accordance with the Act’s standards. If done well, this “good performance” list could reward strong anti-corruption efforts. This structure allows the U.S. government to at least indirectly highlight, by omission from the good performance list, which governments are not making or sustaining good progress. The Act also requires the State Department to provide Congress a classified list with more information on the “poor performance” governments.
The assessments underpinning both lists should inform U.S. policy formulation and action, and to that end, the Act mandates certain follow-up actions. First, the U.S. government must consider imposing targeted Global Magnitsky sanctions on individuals and entities in countries on the classified poor performance list and report any such action. Second, for each country on the poor performance list, the State Department must designate and train a U.S. Embassy point of contact responsible for promoting the implementation of a whole-of-U.S. government anti-corruption approach in that country. Finally, while the Act does not require a formal self-assessment of the U.S. record like the TIP report, it does call for “an annual update in a classified setting [to Congress]…on the United States Government’s efforts to fight against corruption.” It is unclear whether the Trump administration will provide any public update given that the statute only requires the update to be made to Congress.
In the Background: U.S. Actions on Anti-Corruption
The impact of any U.S. praise or criticism on anti-corruption abroad will depend heavily on the U.S. government’s credibility on the issue. Some U.S. shortcomings on anti-corruption are not new, of course, as reflected by longstanding criticisms of the campaign finance system, the Supreme Court’s narrowing of the application of anti-bribery laws, or unheeded calls to ban the trading of individual stocks by legislators. This year, several Trump administration actions defy a number of the benchmarks that the Act outlines as indicators of foreign government efforts to address corruption. For example:
• “Vigorously investigate, prosecute, convict, and sentence public officials who participate in or facilitate corruption” and “convict and sentence persons responsible for… acts [of corruption].” So far, President Trump has pardoned a large and growing number of corrupt politicians and business leaders, signaling tolerance for corruption rather than concern about it. The Administration has also dropped bribery charges against a sitting mayor that it concedes are well-founded and slashed its own capacity to bring such cases. It has significantly narrowed the scope of enforcement of the Foreign Corrupt Practices Act (FCPA). Furthermore, President Trump has publicly demanded the Justice Department indict his political foes, casting doubt on the legitimacy of the actions DOJ takes.
• “Adopted measures to prevent corruption…” An international expert review recently expressed concern that the President and Vice President have long been exempt from certain legal provisions on conflict of interest and integrity, highlighting the need for these leaders to voluntarily address these concerns. Exacerbating this problem, President Trump in January revoked a Biden Administration ethics pledge requirement for all political appointees without instituting a replacement. The administration has largely fired the corps of inspectors general whom Congress has charged with preventing and combating waste, fraud, and abuse within executive branch agencies, despite congressional attempts to strengthen their independence. The Administration also withheld funding for the body that coordinates among and provides guidance for inspectors general, only relenting following engagement from Congress.
• “Take steps to implement financial transparency measures,” including “beneficial ownership transparency requirements.” The Treasury Department announced in March that it would not enforce a brand-new rule creating a registry that would identify the true, “beneficial” owners of shell companies in the United States. This reform is specifically required by the 2020 Corporate Transparency Act and had been called “the single-greatest anti-corruption step the U.S. had taken in decades,” given its potential to reveal a wide range of corrupt and illegal acts.
Beyond these concerns with domestic anti-corruption issues, the administration has dramatically reduced longstanding U.S. efforts to counter corruption globally, such as by decreasing communication about anti-corruption policy, cutting staff, and scaling back anti-corruption foreign assistance. In contrast to past administrations, including Trump’s first term, Trump’s recently-released National Security Strategy does not mention corruption once. Several additional domestic and foreign policy actions are detailed in Just Security’s Anti-Corruption Tracker.
Next Steps After the Act is Published
In advance of the first Combating Global Corruption Act reports due this month, members of Congress, civil society groups, and private sector stakeholders should consider four lines of effort for holding the administration accountable for implementing the Act and its standards effectively.
1) Scrutinize the reports, amplify conclusions that are credible, and highlight conclusions that are not. In reviewing the reports, observers should specifically examine:
• Whether the determinations are insulated from political pressure: Look for indications that decisions are being shaped by personal alliances or domestic politics rather than objective criteria. This could be identified by signs of the U.S. government awarding unearned praise to friendly governments or omitting progress by political adversaries. Congress should also review the classified reports for any unmerited exclusion of political allies or inclusion of political foes.
• Whether the process is adequately staffed and resourced: Thin staffing or limited expertise can weaken the underlying analysis and erode the report’s credibility. The Department should share information with Congress about how it resourced the report-writing process. If it does not, Congress should require this information.
• Whether the evaluations reflect rigorous technical assessment: Determinations should be grounded in well-supported reviews by U.S. experts at embassies and in Washington. This means justifications should accurately outline how the governments do or do not adhere with the standards laid out in the law.
2) Track the Act’s Implementation: Following the completion of the reports, the value of the State Department’s analysis and determinations will diminish if it does not effectively implement the Act’s requirements for considering sanctions and designating and training key U.S. embassy personnel. The Trump administration has been lifting sanctions on corrupt actors, rather than imposing them, making it hard to be optimistic on that count.
Stakeholders should track any sanctions that appear linked to the reports and urge additional action where appropriate. Further, Congress should conduct oversight on whether the Department is properly deploying sanctions for countries on the classified poor performance list and how the Department is approaching training. Finally, the administration should use its discretion to publicize its views on governments that are not meeting the standards, wherever constructive, and more generally should use the reports to inform policy decisions.
3) Strengthen the Combating Global Corruption Act itself. For example, Congress could amend the Act to require the State Department to brief Congress in a public forum on its findings and efforts. The Act could also provide more specific guidance on the training required for points of contact at U.S. embassies. Some technical clarifications would be helpful, too, including specifying the reporting period to be covered and confirming that the good performance list should include governments maintaining a good status quo or making or sustaining progress.
Separately, several members of Congress proposed a version of the CGCA earlier this year that would institute a tiered review for all countries, as the Act was originally designed. If Congress considers this new bill, which would require all of the State Department’s rankings to be public, it should still allow the Department to submit supplemental information or analysis on a classified basis, as needed. It should also include an explicit requirement that the U.S. government assess itself on the Act’s standards, akin to the TIP report.
4) Urge the Trump administration (and future administrations) to adhere to the standards in the Act and articulate how it is doing so. If it does not, civil society and Congress should use the Act’s framework to spotlight U.S. strengths and weaknesses. Leading senators and representatives should hold hearings asking U.S. officials why they have stopped practices that Congress rightly and unanimously urged on other countries through the Act. If committee chairs are not willing to convene hearings, other leading members can and should host shadow hearings aimed at illustrating the costs of U.S. backsliding and spotlighting those harmed by corruption. The hearings could include U.S. constituents whose elected representatives have been compromised by bribery or other corrupt acts; U.S. companies that have faced bribe demands when doing business abroad; and human rights defenders and other advocates from other countries who still want U.S. partnership to fight graft and impunity.
Rebuilding the U.S. government’s anti-corruption practices and making them more durable over the long term will require demand from political leaders and Americans across the country. The Combating Global Corruption Act presents an imperfect but useful opportunity for anti-corruption advocates to keep making the case for why such a fight, at home and abroad, is essential.
Author’s Note: Sky Miller previously served as a civil servant at the State Department, where he worked on early implementation of the Combating Global Corruption Act before being separated in a reduction in force under the Trump administration.
