On December 6, 2021, the Biden Administration released the United States Strategy on Countering Corruption (“Strategy”), the first of its kind. This Strategy reaffirms the Biden Administration’s focus on the fight against corruption and represents the culmination of an interagency review that began in June 2021, after President Biden issued a National Security Memorandum establishing the fight against corruption as a “core” national security interest.

The ambitious Strategy calls for increased inter-agency and international coordination and information sharing with additional resources to be devoted to anti-corruption efforts, as well as the development of new guidance, strategy, and tools to improve the Administration’s goal of combatting corruption in the global economy. The Strategy also targets key gatekeepers to the financial system, including lawyers, accountants, and others, by indicating that the Administration will consider working with Congress to secure additional authorities to cover gatekeepers and will consider ways to increase penalties on gatekeepers who facilitate corruption and money laundering. For example, the Administration plans on working with Congress to fix the current “[d]eficiencies in the U.S. regulatory framework” that allow these gatekeepers to move clients’ funds around without understanding the nature or source of income of their clients.