Holding Kleptocrats Accountable

We remain committed to actively investigating and prosecuting domestic and international corruption, targeting ill-gotten gains, and holding kleptocrats accountable, consistent with our obligations under the UNCAC and other treaties.

Completion Status:
⚠ Unqualified*

*commitment is not specific or/and not measurable

Commitment filtering:

Specific: ❌ no

Based on its wording, this commitment cannot be considered specific because it is too broad in scope. However, after further consultation with the US government, the commitment has been narrowed to “Actively holding kleptocrats accountable, consistent with our obligations under the UNCAC and other treaties”. Kleptocracy is not explicitly mentioned in UNCAC, but “kleptocratic practices” are mentioned in the “Legislative Guide for implementing the United Nations Convention against Corruption concerning confiscating and returning stolen assets”.[1] More specific initiatives in relation to this can be found in the 2021 US Strategy on Countering Corruption:[2]

  1. The establishment of a pilot Kleptocracy Asset Recovery Rewards Programme through the Treasury to enhance the US government’s ability to identify and recover stolen assets linked to foreign government corruption held at US financial institutions.
  2. The launch of an interagency Democracies Against Safe Havens Initiative, supported by up to US$15.1 million and led by the State Department, to engage partner countries to coordinate actions to detect and disrupt kleptocracy, among other objectives.[3]
  3. The launch of USAID’s Global Accountability Programme, backed by US$11.5 million, to support highly vulnerable countries to prevent, detect and mitigate corruption and build regional networks for joint action against transnational kleptocracy, illicit finance and strategic corruption.[4]

The commitment refers to three concrete anti-corruption initiatives to hold kleptocrats accountable, and is therefore considered specific.

[1] United Nations Convention against Corruption (UNCAC) (2012), Legislative guide for the implementation of the United Nations Convention against Corruption, p.193, https://www.unodc.org/documents/treaties/UNCAC/Publications/LegislativeGuide/UNCAC_Legislative_Guide_E.pdf

[2] The White House (2021), United States Strategy on Countering Corruption,https://www.whitehouse.gov/wp-content/uploads/2021/12/United-States-Strategy-on-Countering-Corruption.pdf

[3] US Department of State (2021), US Department of State Announces Initiatives to Bolster Democracy and Defend Human Rights in Support of the Presidential Initiative for Democratic Renewal, https://www.state.gov/u-s-department-of-state-announces-initiatives-to-bolster-democracy-defend-human-rights-in-support-of-the-presidential-initiative-for-democratic-renewal/

[4] The White House (2021), Fact Sheet: Announcing the Presidential Initiative for Democratic Renewal, https://www.whitehouse.gov/briefing-room/statements-releases/2021/12/09/fact-sheet-announcing-the-presidential-initiative-for-democratic-renewal/

Measurable: ❌ no
The commitment is measurable based on whether:

a)     The Kleptocracy Asset Recovery Rewards Programme has been created

b)     The Democracies Against Safe Havens Initiative has been launched, including the provision of up to US$15.1 million

c)     The USAID Global Accountability Programme has been launched, including the provision of US$11.5 million.



Last updated: 31 December 2022
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