The Biden Administration is taking over the reins of government with vigor and focus. The Department of Justice, the Treasury Department, the State Department and the Commerce Department are expected to coordinate closely in an important objective – international anti-corruption efforts. 

What will this mean?

• DOJ will increase its focus on FCPA enforcement, Anti-Kleptocracy cases, Anti-Money Laundering, International Trade Sanctions;

• The Treasury Department’s Office of Foreign Asset Control (OFAC) will increase economic sanctions against corrupt individuals and entities, and AML enforcement by FinCEN will increase with enactment of the AML Act of 2020 as part of the National Defense Authorization Act;

• The State Department will adopt travel and visa restrictions, and increase sanctions against corrupt leaders, individuals and entities; and

• The Commerce Department will increase export control sanctions against corrupt individuals and entities (Denied Parties List).

As a priority item for its foreign policy, the Biden Administration will increase coordination at all levels of the government, including law enforcement resources, financial information sharing, and intelligence sharing. 

As a recent example of the Biden Administration’s focus, the United States placed a travel ban on Ihor Kolomoyskyy, a Ukrainian oligarch and former owner of PrivatBank.  Kolomoyskyy has long been targeted for corruption and money laundering of billions that he allegedly stole from PrivatBank. 

Kolomoyskyy is the former governor of Dnipropetrovsk, a Ukrainian province, who allegedly used his political connections and power for personal gain.  The State Department cited Kolomoyskyy’s current efforts to derail Ukraine’s democratic institutions.

The Justice Department has an ongoing criminal investigation of Kolomoyskyy for money laundering and another PrivatBank owner, Gennadiy Boholiubov, involving the theft of $5 billion from PrivatBank as part of an illegal loan scheme.  DOJ’s is focusing on the period of 20098 to 2016, when the illegal loan scheme was uncovered after the bank was nationalized.  The proceeds were allegedly used to purchase hundreds of millions of dollars in real estate and businesses in the United States.  As part of the Kleptocracy Initiative, the Justice Department has filed civil complaints to seize various assets in the United States.  Kolomoyskyy and Boholiubov are fighting these actions.

As another sign of a growing international consensus on fighting corruption, the United Nations General Assembly will hold its first-ever special session focused on corruption.  International meetings, such as G-7 and G-20 countries, are expected to increase attention to the fight against corruption.