Although the Trump administration has manifestly deprioritized the fight against corruption both at home and abroad, corruption remains a central foreign policy problem because of its role in creating instability and opportunity for malicious actors. The passing references U.S. officials make to the issue, such as in speeches and visa restriction actions, pale in comparison to the litany of credible allegations of inappropriate behavior on the part of senior officials and the president himself. And abroad, overall, the administration’s stance appears to be at best a shoulder shrug to corruption’s challenges and – for some officials – a naked embrace of corruption’s personal and political benefits.
This is a shift from what has long been a bipartisan position that American political, economic and security interests are advanced through anti-corruption efforts. Administration after administration has maintained – even if just as a goal – that countering corruption globally is important for creating a level playing field for U.S. businesses abroad, protecting the U.S. financial system from corrupt activity, and promoting political stability and reliability. Further, there has been an increasing recognition that corruption presents a range of national security risks. It opens space for terrorists and criminals to operate, betrays national sovereignty to adversary states seeking to exploit corruption, and props up authoritarian regimes, as former Senator Rubio once observed.
The United States should re-embrace the importance of anti-corruption in its foreign policy. As Coordinator on Global Anti-Corruption during the Biden administration, I worked across the government and with foreign partners to make some progress on this front, albeit imperfectly. We undertook internal reforms to make our policy and tools more coherent, thoughtful, and agile. We led dedicated initiatives to uncover and combat corruption, prevent corrupt actors from using the U.S. financial system, and shield U.S. businesses from corruption. I am skeptical that such a change could happen under the current administration; still, reflecting on the current anti-corruption landscape, I believe there are lessons we can draw on to improve our effectiveness and reinforce the value of countering corruption as a national security imperative in future ones. These lessons fall into four categories: we spread ourselves too thin, underinvested in accountability, moved too slowly when conditions changed, and did too little to address corruption at home. But each also points to a fix, which I lay out below.
Lessons Learned
1. We were working hard and smart, but not smart enough.
The U.S. government’s anti-corruption enterprise spanned the gamut from supporting law enforcement operations to development support to public awareness campaigns. Offices throughout the U.S. government worked with foreign governments, individual NGOs, banks, companies, and international organizations like the United Nations to advance the agenda, consistent with an ambition to engage in a multidisciplinary anti-corruption effort.
In practice, though, the U.S. government too often prioritized span over depth and reach over results. Spread across multiple agencies and multiple priorities, the U.S. government’s foreign assistance investment was not as impactful as it might have been. For years, bureaucratic territorialism, inertia, and complexity have at times driven redundancy and siloed planning, both in Washington, D.C. and at posts abroad. A lack of investment in shared frameworks and evaluation, particularly of impact, resulted in inadequate learning and disjointed planning processes. Ambition and idealism led to stretched resources, especially because it was hard to say “no” to objectively good ideas. And the absence of high-level political engagement, and an occasional reluctance to pursue anti-corruption actions that would ruffle diplomatic feathers, limited the effectiveness of the overall campaign.
By the end of the Biden administration, the U.S. government had made some progress in addressing how to prioritize our work. At the State Department, we were working through a process to focus resources in specific countries to deal with the most salient problems. We also completed a multi-year effort to map out with greater precision the sorts of existing programs underway and use that common picture to identify redundancies and gaps in coverage. In some places, such as Ukraine, there was also sustained political will to prioritize anti-corruption and to resource it both financially and politically. Nevertheless, there was substantial room to improve.
Today, there is no indication that the Trump administration has pursued any such improvements since coming into office. Indeed, the Office of the Coordinator on Global Anti-Corruption, which I led, ceased to exist in April 2025, and several other offices and agencies focused on countering corruption have lost staff and resources.
2. We underprioritized accountability.
U.S. anti-corruption policy invested heavily in prevention and institution-building, but too often stopped short of ensuring that those who benefited from corruption actually received consequences. That gap was particularly striking because the demand for accountability was among the clearest messages we heard from the people confronting corruption firsthand. In several conversations with civil society, businesses, and even government partners in countries we visited, one message was clear: foreign populations want accountability for corruption, and they want U.S. support in achieving it. By accountability, we mean a proper rendering of consequences for corrupt action, whether within a foreign jurisdiction’s political or justice system or through external tools such as U.S. law enforcement and justice processes, financial sanctions, or visa restrictions.
To advance accountability, the U.S. government worked across agencies to help reform foreign government institutions, to execute transnational law enforcement operations (including through organizations such as the International Anti-Corruption Coordination Center), and to deny access to the United States as a safe haven through use of sanctions and visa restriction tools. Some of these accountability steps were significant – such as the decision to impose sanctions on Horacio Cartes (former president of Paraguay) and Antal Rogan (senior advisor to former Prime Minister Victor Orban of Hungary) – while others were under the radar, working with partners to pursue their own investigation. (Of course, sanctions on both of these individuals were subsequently rescinded without any adequate explanation by the State Department other than that they were no longer seen as consistent with our foreign policy, making one question – at the very least – where fighting corruption fits into that policy.)
Still, accountability support requires more resources and commitment than we were prepared to push. We missed opportunities for foreign assistance investments and could have done more to work with foreign law enforcement and associated intel organizations. It was laborious to try to improve the prioritization of intelligence gathering and analysis on corruption, despite its manifest utility in supporting accountability efforts like sanctions, though some limited progress was made toward the end of the Biden administration.
And, we could not focus sufficient sanctions resources on priority cases where reinforcement of existing sanctions, expansion to include enablers of corrupt individuals, and intensification of consequences on bad actors might have had an impact. Ironically, targeted financial sanctions and travel bans might be among the most effective measures that one could apply against corrupt individuals, as they deny such actors the benefits of their crimes. But, given limited resources and the many other priorities that existed in the U.S. government for sanctions use, the result was too few anti-corruption designations per year to cover key jurisdictions or problem areas.
Anti-corruption institutions are difficult to sustain when corrupt actors continue to operate with impunity. Prevention, transparency, and institutional reform remain essential, but they are more credible when paired with a realistic prospect of consequences. Underinvestment here is also a shame because, in addition to minimizing our anti-corruption impact, we also lost the ability to advance other priorities such as countering narcotics trafficking and terrorism that are often supported and facilitated by foreign corruption. Arguably, we’ve gone backwards in this regard as well now, with the effective derogation of the beneficial ownership database requirements of the Corporate Transparency Act. Now, instead of gathering information on who owns the companies operating in the United States to support law enforcement and deter criminals, we are reopening the door to illicit finance and associated corruption.
3. We were nowhere near as nimble as we should have been.
Anti-corruption conditions can change quickly but U.S. assistance and decision-making structures generally do not. When opportunities arose, crises struck, or reforms stalled, we often did not respond with anything like the flexibility or agility necessary. That flexibility matters because anti-corruption assistance is highly dependent on conditions on the ground. Meaningful reform generally requires credible domestic partners, and continuing to fund government institutions that lack the willingness to reform can waste resources or even reinforce the systems the United States is trying to change. Former Ambassador to Zambia and current Deputy Assistant Secretary of State for International Narcotics and Law Enforcement Michael Gonzales makes a strong argument that for any support to be effective, we need a committed partner on the other side. Continuing to fund government institutions that lack that commitment can waste resources or, worse, reinforce the very systems we are trying to change. The Biden administration recognized this in response to judicial corruption in El Salvador, for example, by pivoting funding from El Salvadoran government agencies to civil society.
But, it is frankly difficult to make those sorts of adjustments given the structural issues involved in U.S. budgeting and the policy or personal dynamics involved in shifting around resources. We must also seriously consider the risks of moral hazard and steward taxpayer dollars accordingly.
To the first point, moving congressionally-appropriated money around is often difficult by design and for good, constitutional reasons. The current administration is showing some of the perils that come from ignoring congressional appropriations, whether as it relates to foreign assistance appropriated or the misuse of taxpayer dollars altogether. But, the solution to a rampant, malfeasant abuse of congressional appropriations is not to make it impossible for law-abiding administrations to adjust funding as circumstances change.
When there are windows of opportunity, reforms are not forthcoming, or money is being futilely spent, it is in the U.S. interest to be able to repurpose funds more quickly. After all, anti-corruption funding is scarce and there is intense competition for its use; spending U.S. taxpayer dollars in anti-corruption programs that have little chance of making a contribution is not only wasteful, it is also a distraction for those implementing and supervising these programs. Making these decisions can be particularly challenging in anti-corruption work because meaningful and durable improvements can take time, necessitating some patience in execution but speed in getting them started.
In the case of Guatemala, we can see the benefits of moving quickly but also the difficulties in doing so. When the Guatemalan government was growing mired in corruption and dismantling institutions like the International Commission against Impunity in Guatemala (known as CICIG for its Spanish acronym) under the presidencies of Jimmy Morales and Alejandro Giammattei, it took time to reposition funding and support to civil society actors in Guatemala. Then, when Bernardo Arevalo was elected, the United States was quick to take action to ensure that he would not be denied office. But, it was harder to surge resources into Guatemala to support the democratic transition and associated institutions. Of course, the Biden administration did try to do a lot to support President Arevalo upon his election in 2023. But, primarily given the long-term nature of other commitments to other countries made by the U.S. Department of State and USAID, it was nowhere near as much as it could have been.
Still, deciding to end support for a foreign government or even a country program focused on civil society actors brings tradeoffs and risks, too. The absence of engagement can increase the potential for security threats or internal instability with ripple effects. Further, such an admission of failure could be perceived as a surrender to corrupt actors, taking the wind out of the sails of champions and civil society organizations with real chances to achieve change; it could even expose those people to risk of retribution if the government involved believes the United States would look the other way. Yet, providing such funding with little prospect of near-term improvement also risks depriving other countries and their civil societies of valuable resources.
4. Our own house is still too dirty.
U.S. shortcomings matter in two ways: weaknesses in our own financial and legal systems can enable corrupt actors abroad, while failures to address corruption and conflicts of interest at home undermine our credibility when we ask other governments to do so.
I often spoke with humility in fighting corruption given our own national issues with corruption and its enablers, across the political spectrum. I cannot imagine how difficult such a conversation would be today after the first 20 months of the Trump administration.
The United States itself has long provided avenues through which the proceeds of foreign corruption can be hidden, moved, or protected.
Even our positive words and actions – such as the Treasury Department’s important steps to enforce the Corporate Transparency Act (CTA) and other financial integrity measures – did not minimize many countries’ views that the United States contributes to an environment receptive to transnational corruption and its enablers. Our refusal to pass a version of the Enablers Act or properly resource the Financial Crimes Enforcement Network meant that countries often said that we were a source of their problems without being part of their solutions. And now, the Trump administration is willfully flouting its legal obligation to enforce the CTA, again undermining global anti-corruption efforts by allowing vulnerabilities for illicit finance by U.S. corporations and Limited Liability Corporations (LLCs) to persist.
Other longstanding weaknesses in U.S. anti-corruption and ethics laws have also hurt our credibility abroad. Examples include the absence of senior executive ethics rules and enforcement, Congressional stock trading allowances, and campaign finance issues. As documented elsewhere in Just Security’s When the Guardrails Erode series, the United States has regressed on a range of anti-corruption standards under the Trump administration, and the ability to exploit these gaps is more visible.
Lessons Applied
To fix these issues, I suggest some potential solutions. This administration’s record makes it extraordinarily unlikely that such a commitment is plausible in the near-term. Thus, these recommendations are targeted at Congress and future administrations that might make a sincere effort at anti-corruption.
At least four things ought to be part of the solution:
1. Institutionalize regular strategic planning for anti-corruption and assign clearer roles and responsibilities to and within agencies.
The White House should be willing to make hard decisions about how to prioritize and oversee the whole-of-government strategic planning on anti-corruption, with close agency consultation, and then execution by agencies –– similar to the Biden administration’s National Strategy on Countering Corruption. But this process should include a detailed and firm delineation of priorities, roles, responsibilities, and action planning processes. This will make it easier to execute priorities globally and at a country level, help minimize overlaps, redundancy, and territorialism, and ultimately ensure that U.S. contributions are meaningful and not spread too thin.
Anti-corruption development support can and should remain available to facilitate institutional reform, equipment purchases, and the like. Still, it should be seen as what it is: a long-term investment that should only be made in countries where there is long-term potential and a genuine commitment by government actors. In countries where there is no such commitment, the priority investment must be in sanctions accountability measures and justice processes to break corrupt actors’ hold. In some cases, the focus should be on defending and supporting anti-corruption champions in-country, as the Biden administration did through various assistance programs and its Anti-Corruption Champions Award.
To ensure effective implementation, the White House should remain engaged during implementation and gauge progress, including through more robust performance evaluation. Building on work in the Biden administration, it should also prioritize more robust in-country planning processes in priority countries. Finally, Congress should conduct proper oversight on the strategic approach and execution, direct funding authorities, and issue mandates as appropriate. Given the Trump administration’s choice to abandon or diminish many past bipartisan practices, this may be critical.
2. Put our money and political capital where our mouth is.
We should recognize anti-corruption as a relatively low-cost way to ameliorate a range of security and other foreign policy challenges, certainly as compared to the alternatives that can manifest when corruption helps to foster narcotics trafficking, criminal enterprise, and terrorism. Then, we should invest in it, with both money and political capital, sufficient to ensure adequate coverage and focus. As a baseline, we should have sustained, serious, and well-resourced support for sanctions and visa restrictions efforts and our own law enforcement focus on transnational corruption. This would include sufficient resources to the International Anti-Corruption Coordination Center (IACCC), U.S. staff covering sanctions and visa restrictions, financial crime enforcement and asset recovery, and intelligence collection.
Resources alone will not be sufficient. Senior officials must also be willing to incur diplomatic costs when significant corruption cases implicate politically important partners or compete with other foreign-policy objectives. Where the investment is prudent, we should invest in foreign assistance to governments and civil society to advance in-country and transnational anti-corruption efforts, including promoting domestic accountability and prevention systems. This includes seizing on windows of opportunity like Guatemala or investing more in recent bright spots, such as Jordan, Moldova, or the Seychelles. For maximum impact, several changes have to be made: we cannot and should not be the lone anti-corruption enforcer, we have to make our investments and decisions more evidence- and results-based, and we have to message effectively that foreign commitment to anti-corruption is a U.S. priority equal to other national security requirements, not one to be abridged out of convenience. Finally, we should devote high-level political capital to diplomatic engagement, including when anti-corruption priorities are at odds with other priorities like critical minerals or security partnerships.
3. Adopt more flexibility in authorities and implement quick decision-making.
Congress and the executive branch should develop lawful mechanisms that allow resources to be redirected when existing programs are no longer effective and surged when genuine windows for reform emerge. That could include contingency funding, greater transfer or reprogramming authority subject to congressional notification and oversight, and mechanisms for rapidly deploying technical assistance, investigative expertise, and other personnel.
Since multiple agencies are involved in the anti-corruption effort and use a wide array of tools, we need a way to assess the effectiveness of our interventions and to help decide next steps. We already have one tool for doing so: the report required under the Combating Global Corruption Act (CGCA). This bill, which passed into law in 2023, requires the State Department to evaluate and report to Congress annually until 2032 about progress being made in fighting corruption. A public report covers good progress; a private, classified report covers countries where there are continued problems and/or backsliding.
Although State’s first released report was late and underwhelming (omitting countries like Sweden, for example, where anti-corruption efforts remain strong), the report remains a conceptual basis for making serious funding and support decisions. As part of its analysis and reporting process, State should identify those countries where more support would be beneficial or where continued efforts would waste U.S. resources. This should be accompanied by a request to redistribute any associated funding where a specific legislative requirement is in place or notification of an intent to repurpose funds where there is already some discretion. Importantly, State’s report should be developed with the support of other U.S. agencies in a process facilitated by the White House in its role as the coordinator of U.S. foreign anti-corruption policy. In cases where there are rapid changes on corruption issues, the White House, agency leadership, and embassies should run quick decision-making processes, building on past practice while innovating on how we collect and use evidence.
Congress should also invest in the sorts of tools and intelligence support available to target corrupt actors abroad. More flexibility in sanctions tools to decide whether asset freezes or travel bans are appropriate in all cases, and how to create conditions for sanctions removal in exchange for restitution by corrupt actors, would be especially welcome.
4. Take more action at home.
The United States, across branches of government and at federal and state levels, must confront the ways we enable or permit transnational corruption here at home. We should pass the Enablers Act to make it harder for service providers in the United States to help corrupt actors loot their countries and exploit our friends. We should properly enforce the CTA, the Foreign Corrupt Practices Act, the Foreign Extortion Prevention Act, and the CGCA. We should recreate and invest resources into the Department of Justice’s anti-kleptocracy efforts and similar structures elsewhere in government. If there are good faith, practical and serious suggestions from the private sector and others to make these tools more efficient, they should be incorporated. But the imperative should be on cleaning up the mess we have created.
To practice what we preach, we must reverse backsliding and recommit to countering corruption at home, consistent with standards in the CGCA that we have established for foreign countries. Examples include: ensuring proper resourcing for domestic anti-corruption investigations, prosecutions, and government oversight; undertaking campaign finance and conflicts of interest reforms, including for the President; limiting Congressional stock trading; responding to the indications of rampant participation in prediction markets by U.S. officials with insider information; implementing anti-corruption safeguards for cryptocurrency; defending civil service protections, and many others.
Conclusion
Apathy in confronting corruption is common. It is seen as too hard a problem, one that has long been with humanity and is impossible to vanquish. That is likely true in an absolute sense, but as with other behavior we consider harmful to society, like theft, we should still try to prevent or combat it as much as possible. Even facing challenging global realities, we can remain true to such principles. The pernicious costs of corruption — to security, economic prosperity, political order, and beyond — make it well worth the effort.
Author’s Note: Special thanks to Schuyler Miller, former Policy Advisor to U.S. State Department Coordinator on Global Anti-Corruption Richard Nephew, for his contributions to this article earlier this year.
