CORRUPTION IN CONFLICT

• Develop and share information on and assessments of the forms of
host country corruption that pose the most immediate, costly, and
mission-critical threats.
• Collect and consolidate best practices and research in the field of
anticorruption, including diplomatic, legal, and assistance tools.
• Provide operational and programmatic guidance to field staff.
• Coordinate anticorruption policies, programs, and practices with
relevant interagency counterparts.
• Identify, track, and provide analysis on initiatives in fragile
states—and in neighboring countries—that have been successful
in addressing corrupt practices, such as aid conditionality, civil
society strengthening, and transparency initiatives.
• Identify appropriate metrics to assess the risks to
U.S. programs from corruption and the success or failure of
U.S. anticorruption efforts.
8. The President should consider amending Executive Order 13581,
which authorizes the listing of transnational criminal organizations
on Treasury’s Office of Foreign Assets Control (OFAC) Specially
Designated Nationals list, to include individuals and entities who
have engaged in corruption and transferred the proceeds abroad.
The revised authority should:
• Amend Section 3(e) of Executive Order 13581 to expand the
definition of a “significant transnational criminal organization”
to include individuals and entities which are engaged in corrupt
practices in conflict zones or during contingency operations.
• Align with and draw upon the Justice Department’s ongoing
Kleptocracy Asset Recovery Initiative, to include setting conditions
for implementation of the executive order.
9. In international engagements related to contingency operations,
the U.S. government should bring high-level political commitment
to bear against corruption to ensure anticorruption is a priority
from the outset for the host government and international and
regional partners. In this respect, the U.S. government should:
• Emphasize the importance and priority the U.S. government
attaches to the fight against corruption and the vulnerabilities to
corruption observed in such environments.
• Set expectations in initial agreements with the host government
regarding its anticorruption commitments and strategy.
• Collaborate with the host government to establish milestones or
key indicators of progress.
• Work with international partners to establish anticorruption as
a continuing priority and encourage partners to support the host
government in carrying out its anticorruption commitments.
• Work with regional partners who have demonstrated success in
fighting corruption in similar operating environments, to bring such
partners’ experiences and best practices to bear.
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