June 09, 2021

On June 3, 2021, President Biden issued a National Security Study Memorandum declaring the fight against corruption as a core US national security interest. To develop a presidential strategy to bolster existing anti-corruption efforts, the memorandum directs the National Security Advisor, in coordination with the Assistants to the President for Economic and Domestic Policy, to conduct a 200-day interagency review and submit a report with recommendations to the President. The release of this memorandum portends active enforcement of the Foreign Corrupt Practices Act (FCPA) and other anti-corruption laws and regulations by the Department of Justice, the Securities and Exchange Commission, and other agencies. Although FCPA enforcement efforts remained quite active during the prior administration, the memorandum suggests a possible uptick in FCPA enforcement activity under this administration, as well as a renewed commitment by the United States to serving as a global anti-corruption leader, including as part of the Organisation for Economic Co-operation and Development, where the United States has traditionally played an active role.

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