During his first term in office, U.S. President Donald J. Trump drew criticism for profiting from events held at Trump-branded golf courses and housing foreign delegations at his pricey Washington hotel. 

But upon his return, he has blown past all precedents on personal enrichment while also overseeing the systematic unraveling of American anti-corruption laws, institutions, and norms. 

While many of these moves have been enforced by the U.S. government’s executive branch, the Republican-led Congress has done little to stop the slide — and, in some cases, has even encouraged it.

So when U.S. voters head to the polls on November 3 for midterm elections, it is not just control of the House of Representatives and the Senate that is at stake, but the future of efforts to contain corruption at home and abroad. 

On the eve of the election, OCCRP spoke to experts to take stock of the state of U.S. corruption — and the fight against it —  today, whether Democrats have a plan to reverse course, and what the repercussions of Trump’s actions have been at home and abroad. 

The White House did not respond to requests to comment in time for publication.

How has the U.S. approach to fighting corruption at home changed under Trump?

Since returning to the White House in January 2025, Trump has taken a wrecking ball to anti-corruption programs and policies that have long been a source of bipartisan consensus. 

One of the president’s first moves involved the mass firing of 17 inspectors general — non-partisan officials whose job it is to investigate misconduct, waste, fraud, and abuse across different government agencies and report back to Congress. 

At least 22 inspectors general were removed during Trump’s first 18 months, and as of a week before the midterm elections, 27 posts remained vacant.  

The administration didn’t provide a reason for their firing or notify Congress at the time, which a federal judge later ruled was unlawful.

The administration has also paused and weakened several key pieces of anti-corruption legislation, including a landmark 2021 law that sought to combat the flow of illicit finance through the U.S. by requiring companies to report their ultimate beneficial owners, known as UBOs.

Known as the Corporate Transparency Act, the law was meant to prevent criminals and kleptocrats from secretly stashing their wealth behind anonymous shell companies. 

But this past August, the Treasury Department issued a new rule that dropped the disclosure requirement for U.S. companies and individuals, calling it a “burdensome reporting requirement.”

(This week, more than 20 U.S. states sued the administration over the rollback, arguing that laws passed by Congress can’t be undone by rulemaking.)

Erica Hanichak, co-director of the FACT Coalition, which advocates for rules to combat financial crime, describes the curtailing of the law as one of the ways the U.S. has “undeniably stepped back its fight against dirty money” over the past two years.  

The consequences are far-reaching — and run contrary to the goals of law enforcement and other national security officials, she said. 

When UBO information is kept secret, it makes it “harder for law enforcement and intelligence officials to follow the proceeds of financial crime, thereby handing a major win to cartels, U.S. adversaries, corrupt politicians, and fraudsters.” 

In one recent example, the U.S. watchdog on federal spending noted that the lack of such data is hampering the ability to detect fraud in government contracting, leaving “hundreds of billions of federal dollars” vulnerable to “beneficial ownership-related fraud risks.”

Last year, the Justice Department prosecuted 11 people tied to a Russian transnational criminal organization that exploited the weak ownership reporting requirements to fraudulently bill the Medicare system, stealing almost $1 billion. 

The Trump administration has also watered down the Foreign Corrupt Practices Act (FCPA), a 1977 law that makes it illegal for American businesses to bribe foreign officials, and which has also allowed the U.S. government to prosecute and fine foreign companies engaging in bribery if they list their stocks or debt instruments in U.S. financial markets. 

Arguing that the restriction put U.S. companies at a competitive disadvantage, the administration initially paused enforcement of the law and then later published new guidelines that called for focusing on cases that undermine U.S. interests.

According to Richard Nephew, a scholar at Columbia University’s School of International and Public Affairs, the real danger goes beyond what he notes has been a significant decrease in fines and convictions. 

More worrying, he has written, is what “the overall picture signals about whether the United States takes bribery seriously, and how that signal changes the risk calculus for companies deciding whether to comply.”

He pointed to Trump’s own embrace of controversial gifts while in office — the most notable of which has been a $400 million jet from Qatar set to serve as Air Force One.

“When the President of the United States is accepting a gold bar as a gift, it is reasonable to ask whether similar gifts given to other foreign heads of state will be seen as grounds for investigations, much less prosecutions,” Nephew wrote in the law and policy journal Just Security. 

What about U.S. anti-corruption efforts abroad? 

Dating back to the 1960s, successive U.S. administrations have pioneered transparency, good governance, and programs to combat corruption around the world, even if their implementation was uneven and imperfect. But the Trump administration has actively retreated from efforts to curb graft abroad in ways both big and small. 

For instance, it quickly dismantled the U.S. Agency for International Development (USAID), one of the main instruments for funding anti-corruption efforts overseas, and froze the disbursement of foreign funding.

(OCCRP formerly received grants from USAID, and became a plaintiff in a lawsuit against the Trump administration for illegally terminating funding that had been allocated by Congress.)

The State Department’s Office of the Coordinator on Global Anti-Corruption — a post created in 2021 to integrate anti-corruption efforts with Washington’s foreign policy goals — was also eliminated soon after Trump took office, as was the Task Force KleptoCapture, a unit created by the Justice Department in 2022 to go after sanctions evaders, especially Russian oligarchs. The Justice Department said the latter was part of a policy realignment to focus on fighting cartels. 

The administration has also stepped away from smaller but symbolic efforts to stamp out corruption overseas, such as no longer including information about corruption in the State Department’s annual country reports on human rights. (The State Department did not respond to requests to comment). 

And then there’s the controversial use of the Magnitsky Act, which was passed in 2012 to allow the U.S. government to sanction foreigners who engage in corruption or human rights abuses.

The president shocked anti-corruption crusaders last year when he used the Magnitsky Act to sanction a Brazilian Supreme Court justice who oversaw the trial of  Brazil’s former president Jair Bolsonaro, a Trump ally later convicted of plotting a coup after losing the 2022 election.

(The conviction prevented Bolsonaro from running for office, leading his son Flavio to take up the family mantle and narrowly lose a presidential runoff election this past Sunday. Facing a money laundering investigation in Brazil, Flavio fled the country for the U.S.)

“Global Magnitsky was a huge win when it passed … and the human rights community and the anti-corruption community celebrated,” said Gary Kalman, director of Transparency International U.S. 

“Never in our wildest imagination would we have dreamed that a president of the United States would use the Global Magnitsky Act to go after a judge in another country for enforcing anti-corruption laws.”

What about Trump and his family? Have they engaged in corrupt behavior?

U.S. presidents have historically stepped away from their personal business interests to avoid conflicts of interest, or even the perception of a conflict.

Yet Trump’s latest annual financial disclosure — which runs 927 pages long and covers his first year back in office — shows a significant increase in his income while president. Last month, Forbes estimated he was $2.7 billion richer than when he won the 2024 election.

The source of this wealth comes from cryptocurrency enterprises, Trump-owned resorts and real estate, his social media platform Truth Social, and a range of other business ventures, many of which are rife with potential conflicts of interest.

“I don’t think that there’s any president who has so brazenly used their office to create a web of foreign entanglements that enriches himself, his family, and some of his closest advisors and their families,” said Matthew Dallek, a historian specializing on presidential politics at George Washington University.

The examples to choose from are numerous. For instance, the collective Trump fortunes soared earlier this year when an investment firm reportedly connected to the United Arab Emirates’ ruling family bought nearly half of a Trump family-connected cryptocurrency company. 

A company backed by Trump’s sons has also sought to sell drone interceptors to Gulf countries while they were under attack by Iran following a war started by their father. 

Trump and other officials’ frequent visits to the president’s properties, meanwhile, generate advertising and revenue for those businesses — and open up avenues through which others can use their wallets to try to curry favor with the president.  

Taken together, experts have described it as an unprecedented level of political profiteering that raises the risk of the president putting his business interests ahead of those of the country.

It’s also a problem that won’t be easy to fix. 

Trump’s second term has exposed just how much the U.S. presidential system depends on “an adherence to norms and a set of expectations and values…rather than strict rules and laws preventing a president from corrupt actions,” Dallek said. 

In previous comments to the press, a White House spokesperson has stated that “neither the president nor his family has ever engaged — or will ever engage — in conflicts of interest.” When asked about his lucrative year following the release of his financial disclosures this June, Trump attributed the profits to the stock market “going up” and said he never spoke to the people who manage his money.

“We are experiencing what happens when you have an individual who dismisses ethical norms,” said Kalman of Transparency International. “People are now trying to figure out how you close these kinds of gaps in our ethics rules at the highest levels of our government.”

One avenue, he said, is to secure the roles of state actors that could provide a counterweight to the Justice Department, whose independence has been called into question as it has pursued investigations against the president’s opponents and dropped cases involving allies. 

“I think there’s a lot of district attorneys and law enforcement officials that are concerned about what they’re seeing as the weaponization of the Justice Department,” said Kalman. “If the U.S. Justice Department gets taken over by the executive, you have what we have now, which is a lack of accountability or unwillingness to enforce any of the violations that we’ve seen happen.”

The Justice Department did not respond to requests to comment.  

Democrats are trying to take back Congress. What is their plan if they succeed? 

Polls show voters cite corruption as a major concern, and Democrats have pledged to investigate corruption if they regain control of one or both chambers of Congress.

Should they win back at least the House of Representatives, they would be in a position to legislate and hold oversight hearings. They’ve already signaled plans to spotlight the business entanglements of the Trump family and friends, and say they won’t be shy about using their power to subpoena witnesses.

“We can bring in members of the Cabinet and ask them questions and perhaps see if there’s any way we can get rid of some of them,” Rep. Dina Titus, a Nevada Democrat on the House Foreign Affairs Committee, told OCCRP. Her panel will “look at some of this corruption that’s going on around the rest of the world involving the administration and some of their buddies and relatives,” she added. 

Much of what Democrats will be able to do hinges on the size of their victory, and some of their plans have yet to be spelled out in detail. 

“Democrats are running on corruption, but they’re not running on a specific platform of how they’re going to reform or fix the system or address many of Trump’s egregious acts,” said Dallek, the historian. 

In a recent interview with the TV outlet MS Now, New York Democrat Hakeem Jeffries, the current House minority leader, outlined plans for the first 100 days of the next Congress that included empowering two committees to look into corruption.  

He has said the Judiciary Committee and the House Oversight Committee would be tasked with accountability and looking into the Trump family business entanglements.

“We’re going to follow the facts, apply the law, be guided by the Constitution and then let the chips fall where they may,” he said. 

Congressional Republicans, for their part, have prominently used their oversight powers to investigate people named in or associated with the Epstein files, including Commerce Secretary Howard Lutnick. The committee has also investigated tax breaks given to politically opposed non-profit organizations, while their anti-corruption agenda has largely been focused on reversing the “Censorship Industrial Complex,” a term used to describe those they say are suppressing right-wing viewpoints online under the pretense of limiting disinformation. 

Hanichak, from the FACT Coalition, called on the next Congress — regardless of who holds the reins after Tuesday — to “strengthen guardrails to prevent public officials from profiting from power.”

“We are what we tolerate: in most cases, the recent reticence of both Republicans and Democrats to denounce corruption by colleagues in their own parties has bred public distrust about the sincerity of reform,” she said. 

“We need more transparency and accountability — in elections, in our financial system, in government contracts and services — to restore faith that democracy can deliver for ordinary people.”

Source: OCCRP · 2026-10-30

Shortly after taking office in early 2025, the administration of U.S. President Donald Trump paused the enforcement of the Foreign Corrupt Practices Act (FCPA), the nearly 50-year-old law that prohibits American citizens or companies from bribing foreign officials for business.

When the FCPA was resumed six months later, the U.S. Department of Justice was ordered to narrow its focus to limit “undue burdens” on American companies operating outside the country. That action was in line with the Trump administration’s “America First” unilateral approach to foreign policy, which has seen the U.S. withdraw from dozens of international organizations on the grounds that they are inefficient and not in line with the country’s priorities. 

Lorenzo Crippa, a lecturer at the University of Strathclyde who quantitatively studies how recorded instances of corruption affect financial flows, discusses the repercussions of these changes and worrying trends that have emerged under the new U.S. approach to global anti-corruption enforcement.

The U.S. has changed the way it applies the Foreign Corrupt Practices Act, and last month it was announced it will officially withdraw from GRECO, the Council of Europe’s anti-corruption body. U.S. officials reportedly said the government would instead use unilateral tools like sanctions and visa restrictions to fight corruption, which they described as more effective. Based on your research, do you think the rejection of collaborative global standards in favor of mechanisms a country controls itself can be more effective?

I would say hardly so. In the anti-corruption space, likely the opposite is true. It’s just enough to look at history: the U.S. adopted the FCPA (Foreign Corrupt Practices Act) in 1977, and for 20 years, the law was basically silent until a global regime on anti-corruption was passed at the OECD (Organisation for Economic Co-operation and Development) with the OECD Anti-Bribery Convention. 

The law was on the books, but it was effectively not enforced, because the fear was that enforcing the law would disadvantage American companies at a time when German competitors and French competitors could even deduct bribes from tax statements.

That all changed with the OECD Anti-Bribery Convention. At the end of the ‘90s, that’s the moment we see enforcement of the FCPA, effectively for the first time.

The same could be said when we think of other areas of governance, more generally. There’s research in political science and international relations that clearly shows that coordination among countries is the most effective way to address global issues, rather than unilateral actions. So, I’m at the very least skeptical that that could be the case.

In unrelated research of mine with some co-authors, we looked at the effect of American sanctions on financial markets, and we find that they can actually backfire for American firms that are connected to the sanctioned entities. So there’s even evidence that a multilateral solution could probably be more desirable.

You co-authored an article in Foreign Affairs this year on how Washington may now be weaponizing anti-corruption law. Many critics of the U.S. say that its laws were hardly neutral before, and often applied for geopolitical or economic leverage, or even amounted to a form of imperialism. How would you respond to that line of argument?

Certainly it’s true that the FCPA had been enforced in the past also for geopolitical reasons. I’m sympathetic to these claims. What has changed is that the approach of the Trump administration seems to be one where American firms get a free pass, and non-American firms would be subject to harsher enforcement. Or at least the expectation seems to be this one. And if that’s the case, this is a significant change from the past.

If we compare it from the past situation, [despite] the fact that non-U.S. firms might have been significantly charged under the FCPA, American firms were still subject to this policy to a full extent. Whereas here, what we’re observing is the possibility of a double standard. That could genuinely be concerning, because that would be outright weaponization.

Like I said, I’m sympathetic with these critics of the FCPA but it did manage to get some massive cases of corruption brought to justice — even of American firms. I think the largest fine in FCPA history is Goldman Sachs. It was certainly far from ideal, but probably closest to the best that was realistically adoptable as an anti-corruption policy. So its reshaping under the Trump administration is, to me, concerning.

What are your specific concerns? What could be the broader effects on corruption around the globe if they don’t target U.S. firms and selectively target non-U.S. firms?

When Trump initially halted enforcement of the FCPA in 2025, I was initially puzzled. The FCPA has been used as a tool of foreign policy as well, so getting rid of this or pausing it altogether, was puzzling to me.

But when the period of pause was over and enforcement resumed, under new revised guidelines, what seems to be the case is that it’s going to be enforced primarily with the purpose of defending American foreign interests. At the moment we just have a handful of new cases after this change in enforcement, which makes it a little bit difficult as of now to understand if that’s really the direction that this is going.

What my co-authors and I found was that at the very least markets seem to have priced in that expectation. We found that the moment the FCPA was suspended, firms that had been targets of FCPA actions in the past significantly experienced a boost in their stock price, which reflects the idea that probably investors expected a lax enforcement environment coming, for the rest of the Trump administration at least. That essentially means putting a bonus on the possibility of corrupt activity. It’s a very robust change that we observe from the moment enforcement was made laxer.

In the past decades, we got used to the idea that corruption was bad for business, that investors would prefer a cleaner firm. These results, at least in this historical moment, seem to indicate the opposite: That these market actors would be willing to bet on more corruption. This is somewhat of a step change when it comes to corporate governance and good governance of business. Then again, this gain in stock price was concentrated on American firms. Non-American firms saw no improvement to their valuation, which seems to reflect this idea that there’s going to be weaponization going forward.

With those same co-authors, you published another paper this year studying the effects of the OECD Anti-Bribery Convention, finding that the drop in bribery by companies who comply with the convention was basically offset by an increase in bribery from non-signatory competitors. What can we conclude from this? Is it casting doubt on whether the OECD convention or any “supply side” treaty targeting bribers can work?

That’s a tricky question, because that paper clearly shows two faces of the same coin. On the one hand, it shows that these treaties are working because they generate strong incentives for those outside the treaty to make the most out of the advantage that they can get. That shows firms covered by the treaty that cannot bribe with impunity. The other face of the coin, that this is offset by corruption from firms outside the treaty, is really concerning. It means that something should be done.

We had a meeting with the OECD working group on bribery about this when we were disseminating the results of our findings. I think they’re very aware of this problem. My main takeaway from this is that the solution is [an] expansion of these treaties. As long as there are double standards, as long as there are firms outside of the treaty who can bribe with impunity, the risk of this leakage (that’s what we call it where corruption sort of leaks to the group of firms outside of the treaty) becomes larger.

Historically, the way this has been solved was by trying to expand participation to the treaty. 
In the ‘90s, that meant having France, Germany, and Japan in the treaty. Right now, probably that means trying to expand to China, Singapore, Taiwan — jurisdictions with firms that are very heavily involved in business, but who can bribe with impunity. I understand that calling for more multilateralism these days seems idealistic, but really that’s the only way that we can ensure that these supply side treaties can work in a sense. 

My research doesn’t do much on this, but existing research of others does show that in the past a strategy has been to use domestic anti-corruption needs of countries. When the OECD Anti-Bribery Convention was signed, the U.S., who was heavily pushing for this treaty, managed to sort of exploit the fact that European countries were facing their own domestic corruption scandals. In Italy, for example, the Mani pulite [“clean hands”] scandal was a big thing in the ‘90s, and that was a significant reason why the U.S. managed to put pressure on this treaty to exist. So if treaty members were able to exploit the fact that, domestically in other parts of the world, there might be a need for more anti-corruption reforms, this could be one lever to try and extend participation. 

I wouldn’t be certain that these [multilateral treaties] are the ideal solutions, but of the ones that have been tried, they seem to have been quite effective. At least in the shape that they used to have, with a multilateral agreement, and within that agreement, the United States playing a significant role in enforcement, for the good and bad that that was. This role as a global sheriff, in a sense, has managed to reduce corruption and bring large cases of bribery to justice. Now, whether that is the ideal solution, I’m not sure. There certainly is evidence that this was working, and jeopardizing that with the recent moves of the Trump administration makes me somewhat worried.

Could the U.S. look to resume its role as “global sheriff” if U.S. President Donald Trump’s Republican Party suffers the kind of losses currently being predicted in polling for next week’s U.S. midterm elections?

There’s a group of senators led by Elizabeth Warren who are trying to propose a bill called the FCPA Reinforcement Act. The idea is to extend the statute of limitations of the FCPA so that it could effectively be protected by future political decisions to halt enforcement again. This specific bill is very unlikely to pass — it’s mostly like a signalling device. 


But under a flip [of congressional power in next week’s elections]  … that’s a hypothetical. [but] Mmy expectation would be that it would counteract the negative effect that we saw on stock market movements at least. By protecting the FCPA from political swings it should reinforce the idea that enforcement is going to happen, and that good anti-corruption governance is the expectation, and that companies and investors shouldn’t deviate from that. So at the very least, I would expect it should reassure markets of that and prevent investors from betting on corruption. I’m not sure this would do much to change this idea of enforcing the FCPA more strongly on non-American companies. I’m not sure that would be something that the bill itself could address. But at the very least, it should remove part of the problem. 

Source: OCCRP · 2026-10-30