February 5, 2023

Volume XIII, Number 36

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February 03, 2023

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February 02, 2023

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DOJ Announces Central America Anti-Corruption Tip Line

On Oct. 15, 2021, the Department of Justice (DOJ) announced the creation of a tip line to help assist its Anticorruption Task Force fight corruption in Central America, specifically in the Northern Triangle countries of El Salvador, Guatemala, and Honduras. The Anticorruption Task Force was established earlier in 2021 with the goal of combatting corruption, human smuggling, and trafficking in the Northern Triangle and Mexico. Assistant Attorney General Kenneth A. Polite Jr. of the DOJ’s Criminal Division said, “corruption and impunity in the region undermine democracy, fuel irregular migration, and pose a threat to our national security because they sustain criminal organizations and transnational crime.”

This DOJ announcement signals that anti-corruption efforts: (1) remain a priority for the Biden administration; (2) continue to focus on Central America; and (3) require the cooperation of multiple U.S. governmental agencies.

Anti-Corruption Priority for Biden Administration

The Biden administration has made anti-corruption a priority. On June 3, 2021, President Biden issued a National Security Study Memorandum (NSSM) that established fighting corruption as a “core national security interest.” The NSSM directed several federal agencies, including the DOJ, to conduct an interagency review and submit a report and recommendations within 200 days of the NSSM. The NSSM’s stated goal is to “promote good governance; bring transparency to the United States and global financial systems; prevent and combat corruption at home and abroad; and make it increasingly difficult for corrupt actors to shield their activities.” The subsequent establishment of the Anticorruption Task Force and the recent creation of a tip line reinforce the Biden administration’s commitment to fighting corruption.

Central America Focus

In June 2021, the DOJ created the Anticorruption Task Force to combat corruption in Central America. The DOJ stated that it would “increase its focus on investigations, prosecutions, and asset recoveries relating to corruption in Northern Triangle countries,” as well as ramp up enforcement efforts in Mexico. That effort includes aiding enforcement agencies and prosecutors in the targeted countries to support in-country prosecutions. These steps follow the FBI’s 2019 creation of a dedicated international corruption squad based in the Miami Field Office, which is focused on the Latin America region.

Anti-Corruption Efforts Are Interdisciplinary

The Biden administration’s efforts go well beyond just U.S. Foreign Corrupt Practices Act (FCPA) enforcement and require interdisciplinary cooperation. The NSSM review involves over a dozen federal departments and agencies, including the DOJ, the Joint Chiefs of Staff, the Central Intelligence Agency, the Department of Homeland Security, and the U.S. Mission to the United Nations. Similarly, the Anticorruption Task Force that the tip line will assist includes representatives from DOJ’s FCPA Unit, the Money Laundering and Asset Recovery Section (MLARS), the Narcotic and Dangerous Drug Section (NDDS), and federal prosecutors from U.S. attorneys’ offices along the southwest border.

Hugo López Coll also contributed to this article.

©2023 Greenberg Traurig, LLP. All rights reserved. National Law Review, Volume XI, Number 300

About this Author

Cuneyt A. Akay Anti-Corruption Attorney Greenberg Traurig Denver, CO

Cuneyt A. Akay is an anti-corruption lawyer focused on helping clients comply with the Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act. Cuneyt designs, builds, and implements effective compliance programs for clients around the world. Cuneyt’s experience includes conducting internal investigations, performing compliance risk assessments, handling pre-and post-acquisition compliance due diligence, training staff and third parties on compliance requirements, and assisting in the monitoring and auditing of anti-corruption programs.

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Kyle R. Freeny Shareholder Anti-money laundering issues Bank Secrecy Act Anti-corruption, Foreign Corrupt Practices Act, Asset forfeiture, Foreign Agents Registration Act FARA, Government investigations,Compliance counseling

Kyle R. Freeny, a skilled trial attorney and former federal prosecutor for the Special Counsel’s Office and the Department of Justice (DOJ), Criminal Division’s Money Laundering and Asset Recovery Section (MLARS), focuses her practice on white collar criminal defense, government and internal investigations, and anti-money laundering (AML) and international corruption matters.

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Jed Dwyer focuses his practice on white collar criminal matters, criminal and civil tax litigation, and other complex civil litigation. Jed has tried more than 40 jury and non-jury trials and has been involved in over 100 investigations and prosecutions, many of which included complex fraud and regulatory matters. Jed leverages his experience to represent individuals and organizations in investigations and other proceedings concerning tax fraud, money laundering, public corruption, complex international financial crime, financial institution fraud, and violations of the Bank Secrecy Act,...