Category Archives: Commentary

Stopping Presidential Family Members Use of the Presidency for Private Gain: Important First Step

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Reports Donald Trump Jr. is personally profiting from his connection to his father prompted U.S. Senator John Curtis to ask the Senate Judiciary Committee to develop reforms necessary to curb such conduct (here).

GAB has queried readers for ideas to help the Committee, and an alert GABer flagged a provision in legislation the House Financial Services Committee approved in April (here) modernizing the Defense Production Act.

Current law gives presidents wide-ranging powers to provide financial help to companies critical for national defense. The provision in the reform bill curbs those powers. It would bar any company not only in which the president, vice-president, or a senior defense official has “a significant interest” from receiving assistance but also any company in which a family member has “a significant interest” from receiving assistance as well. Not a complete solution but a first, and important, step. A sign at least some in Congress are willing to act

The Defense Production Act reform bill awaits a vote of the full House. Good chance for House members to go on record on what they think about family members trading on their relatives’ name.

Text of the section follows.

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Republican Senator Seeks Investigation into Whether Donald Trump Jr. is Profiting Off Ties to His Father

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Senator John Curtis, a Republican from Utah, wrote the Senate Judiciary Committee September 21 asking it to investigate whether Donald Trump Jr., eldest child of President Donald Trump, has used his relationship with his father “for private financial benefit.”

In the letter (here), he writes that

For years, serious questions have been raised about members of presidential families using their names and proximity to the President to advance private business interests.

In a nod to fairness and bipartisanship, he asks the Committee to investigate Hunter Biden as well, but the bulk of his letter recounts the ways Don Jr. has used the family name to enrich himself. From the payment of a lavish wedding afterparty by a Russian oligarch, to his promotion of family-backed cryptocurrency ventures, the pursuit of international real estate deals, several reported investments in defense contracting.

“These reports raise legitimate questions about foreign access to members of a sitting president’s family and whether such relationships can create actual or perceived expectations of favorable treatment,” he writes. He then asks the Committee to “establish the facts, determine whether existing ethics, disclosure, or anti-corruption laws apply, and identify reforms necessary to prevent the presidency from becoming a vehicle for private enrichment by those closest to it.”

The letter is remarkable for two reasons. It puts the question of Presidential relatives trading on their link to the single most powerful individual in the modern world on the agenda at a time when it is likely to engage the public (and hence lawmakers), and it was written by a Republican. It’s unlikely the Committee will act before November, but, particularly if the Republicans suffer a major defeat in November, an investigation will surely be at the top of agenda in 2027.

IMF Report on Ukraine Asset Declaration System: Wasting enormous resources on low value tasks, spending little on those that matter

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No, that is not what the new IMF report on Ukrainian’s asset declaration system says. International organizations are never that blunt. 

But reading the careful, thorough assessment of Ukraine’s most important anticorruption program it is clear that is what the authors were thinking given what they found. And what they did say comes awfully close:

  • “The effectiveness of Ukraine’s [Asset Declaration System] is undermined by an overly expansive and highly formalistic framework that overburdens the [National Agency on Corruption Prevention], weakens prioritization, and limits the system’s capacity to support meaningful detection and recovery of illicit assets.”
  • “[Its] expansive scope, which is unmatched by other European nations, strains the NACP by forcing it to manage one of the world’s largest database of public officials’ assets with highly limited resources.”
  • “The conversion of NACP findings into final judicial sanctions remains limited. In 2025, the NACP transmitted 369 reasoned conclusions to law enforcement for criminal prosecution. These resulted in 12 guilty verdicts, a marked improvement from zero verdicts in 2021, but a conversion rate that remains low relative to the volume of referrals and reflects the broader systemic delays in the judicial pipeline for high-level corruption cases.”

More lifestyle audits

Comparing what officials declare they own to their house they live in, the car they drive, the vacations they take, and other properties they own and expenses they incur is the most effective way to spot if they are corrupt (here). The NACP has a unit dedicated to conducting such audits, but as the IMF report found, not only does the Lifestyle Management (LSM) group have a small staff, but the audits do not focus on priority areas such as 

“. . . war-related procurement and expenditure, where the convergence of significant public resources and reduced oversight creates acute corruption vulnerabilities.”  

The recommendation to audit the lifestyle of those involved in procuring military supplies and equipment comes at a critical time. Confidential reviews by the State Audit Service and an internal Ministry of Defense auditing department show war profiteering has reached unconscionable levels. Front-line troops are being supplied with worthless ammunition while military contractors are reaping huge profits (here).

Lifestyle audits are the surest, fastest way to weed out those officials corrupting the military procurement process. NACP staff now conducting routine checks of the accuracy of low-level officials’ declarations should be reassigned to the LSM unit and ordered to scrutinize the lifestyle of every single individual involved in military procurement.

Ukraine’s supporters in the international community have long recognized that an asset declaration program is crucial to curbing corruption and made its establishment a condition of continued financial assistance. The IMF report provides a roadmap for making the program effective. The international community should insist the government follow that map with haste.

Measure Corrupt Conduct — Not Corruption

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The new Handbook of Research Methods for Corruption Studies, edited by corruption guru extraordinaire Michael Johnston, offers a wealth of learning about how to fight corruption. None more important than Alina Mungiu-Pippidi’s chapter analyzing the fundamental question in the fight: how do we know if we are winning?

Decades after corruption control rose to the top of the global agenda, assaying how well the fight is going ought to be straightforward. That’s not so as the continuing debate about the validity of TI’s Corruption Perceptions Index, the World Bank’s Control of Corruption measure, and the many other measurement tools on offer shows.

The problem, as Professor Johnston acknowledges in the Handbook’s introduction, is foundational.

“After 40 years of debate about corruption, we are still uncertain about what we are talking about. . . cannot measure it directly. [and don’t know if] a single [corruption] score about a whole country really tells us much.”

What Professor Mungiu-Pippidi shows in her chapter is that the foundational problem is behind our inability to measure progress in fighting corruption. That efforts to gauge success have foundered on misguided attempts to propound a universal, all-encompassing definition of corruption which have produced nothing more than vague, imprecise measures riddled with practical and methodological errors. She explains why these should be scrapped and offers in their stead a series of direct, fact-based indicators for evaluating progress tied to a specific, bounded definition.

Professor Mungiu-Pippidi’s chapter deserves the closest attention by policymakers, evaluators, and citizens who want to know if an anticorruption law, policy, or strategy is making a difference. This post builds on and complements her work in two ways.

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Is it Too Late to Corral America’s Wealthy? Casey Michel’s United States of Oligarchy

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The discovery that Anthropic and OpenAI were able to freely roam cyberspace after escaping their sandbox triggered global alarm bells. If AI programs can break out of the electronic guardrails that prevent their running amok, there is no telling what havoc they might wreak.

Casey Michel, Director of the Combating Kleptocracy Program at the Human Rights Foundation, writes about escapees from a different sandbox in the United States of Oligarchy. The escapees: members of America’s billionaire class. The sandbox: the ethics codes, social norms, and laws that constrain the conduct of America’s wealthiest.

Michel recounts the harm Elon Musk, Peter Thiel, and fellow billionaires have already done while operating free of these constraints. He describes the far greater damage likely if those constraints are not soon reimposed and urges reforms to ensure the ultra-rich can never again break out.

Today’s billionaires are not the first to have slipped the sandbox’s guardrails. United States of Oligarchy reminds that the same techniques that fueled the rise of Carnegie, Rockefeller, Stanford and other nineteenth-century “robber barons” – bribes, shell companies, large campaign contributions – have helped today’s counterparts realize unimaginable levels of wealth. But there are profound, startling differences between the two. The first generation of robber barons never made common cause with autocratic regimes; their activities never compromised the nation’s security, and they never rejected the democratic ideal.

That’s the indictment Michel lodges against the current generation, plain by his subtitle: How America’s Wealthiest Ally with Dictators, Weaken the U.S., and Destroy Democracy.

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Review of Robert Barrington’s Corrupted Kingdom

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Corruption now threatens one of the oldest and most established democratic nations. In a 2024 poll, two-thirds of Britons said politics is becoming more corrupt (here), and in 2025 nearly 9 in 10 expressed concerns about potential corruption among politicians (here). Over the past year 16% reported being asked for a bribe, and 11% were asked to facilitate money laundering (here).

U.K. anticorruption fighters are taking heed. None more than Robert Barrington. In Corrupted Kingdom, out July 16 (preorder here), the former Transparency International U.K. head and Chair of T.I. International’s Council chronicles the ways corruption has begun to infect venerable U.K. institutions: from the Monarchy, where the now deflowered Prince Andrew’s flacked for a Kazakh oligarch in return for £ 3 million to Parliament, where MPs are secretly paid to question Ministers and seats in the House of Lords are on offer for hefty campaign contributions, to Scotland Yard, local governments, businesses small and large.

It is even seeping into the academy. Currently Professor of Anti-Corruption Practice at Sussex University’s Centre for the Study of Corruption, Barrington argues that the growing willingness of universities to accept dark money compromises their independence and their integrity.

British and non-British readers will both find much to recommend in the pages of Corrupted Kingdom.

British readers are likely to be most interested in the reforms Barrington advances, from beefing up “dull sounding” but important accountability institutions such as the Auditor General for Wales and the Northern Ireland Audit Office to teasing out whether the U.K. should create a formal, institutional structure, even an independent anticorruption agency, to replace the current arrangement, a patronage position in the PM’s office whose occupant has no official status and whose advice is easily, and often, ignored.

Citizens of other liberal democracies will find (reassuringly or depressingly) that theirs is not the only country where abuses stemming from large donations to political parties orchestrated by lobbyists is a front-page problem. Americans may take some solace from learning that Boris Johnson’s short-lived reign as PM approached Trumpian-levels of corruption.

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Seychelles Constitutional Court Ruling: A Victory in the Global Fight Against Corruption

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In a landmark decision the Constitutional Court of Seychelles refused to dismiss a corruption case against one of the island nation’s most powerful individuals. The Court’s May 14 opinion rejected prominent businessman Mukesh Valabhji’s effort to dismantle the legal foundations of his prosecution.

The decision puts the lie to fears courts don’t have the spine to back prosecutors seeking to hold the wealthy and politically influential to account.

The case arose from what the Seychelles media dubbed the “missing $50 million” scandal. In 2002, the United Arab Emirates gave the Seychelles government $50 million to fund food imports and help overcome a balance-of-payment deficit. But the funds never reached the public purse. Instead, they were apparently siphoned into a UK bank account and later laundered back into Seychelles where they facilitated the corrupt privatization of state-owned hotels under the Compagnie Seychelloise de Promotion Hôtelière (COSPROH).

Defendant Valabhji was at the time the managing director of the Seychelles Marketing Board (SMB) and executive chairman of COSPROH. The prosecution alleges that Valabhji used the siphoned UAE funds to purchase the very hotels he was tasked with privatizing, effectively acquiring massive private assets using misappropriated public money. The Chief Justice of Seychelles aptly noted that these funds “should have ended in the coffers of the Government… and assist in our national development,” but instead “ended up back up in smoke”.

The Anticorruption Commission of Seychelles (ACCS) arrested Mukesh and his wife, Laura Valabhji, and the investigation quickly expanded, leading to the arrest of several high-profile figures, including Sarah Zarqani Rene, the widow of the late President France Albert Rene, and former senior government ministers. The discovery of a massive cache of weapons—including 72 guns and over 43,000 bullets— prompted additional charges of terrorism and illegal arms possession.

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Seychelles’ Case Sets Precedent for Asset Forfeiture

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U.K. Magistrate District Judge Sam Goozée ruled April 22 that the statute of limitations in a civil forfeiture starts to run only when the National Crime Agency learns of the existence of the assets and their illegal origin (here). As a result, he ordered the forfeiture of some $260,000 in the London bank account of Marinette Soumery, a secretary of Mukesh Valabhji, a former Seychelles government official charged with 11 counts of corruption, abuse of authority of office and money laundering (here).

In its forfeiture application, the NCA linked the money to companies and individuals associated with Valabhji and showed he and Soumery had taken elaborate steps to disguise its source. Because of the “highly suspicious” actions taken to hide where the funds came from, their links to Valabhji and associates, and Soumery and Valabhji’s inability to offer a credible explanation for their origin, the court ordered the money forfeited pursuant to the Proceeds of Crime Act, ruling:

there was “cogent and compelling” evidence giving “rise to an irresistible inference that the money in the account could only have been acquired through criminal activity.”

Statute of Limitation Defense

Soumery’s main defense was that however the funds were acquired, the PCA’s six-year statute of limitations, which runs from when “the property was obtained,” had expired in 2007, the date of the last deposit to the account.

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Legislation to Stop President, VP from Abusing Power to Steal Taxpayer Funds

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On April 15 House and Senate Democrats introduced a bill entitled Ban Presidential Plunder of Taxpayer Funds Act. Key provisions include:

  • Ban the sitting President/VP from collecting settlement payments from the United States by prohibiting the President, Vice President (VP), their spouses/children, a trust that exists for their benefit, or an entity they own or control, from collecting damages payments from the United States through a settlement or similar agreement with the government the President/VP leads.
  • Pause the filing and processing of a sitting President or VP’s administrative claims by prohibiting federal agencies from processing or fulfilling damages claims brought by the President/VP. Also, prohibit the President/VP from filing administrative claims for damages while in office.
  • Impose guardrails on the President/VP’s federal lawsuits seeking damages by only allowing the President/VP to collect compensatory damages awarded by a federal court if the court appoints an independent counsel to represent the agency and makes all proceedings public.
  • Cooling-off period during a former VP’s term as President, meaning if a former President’s VP is elected President, impose the same restrictions on the former President while the former VP is still in the White House.
  • Impose guardrails on claims by former presidents/VPs by allowing former presidents/VPs to collect damages from the U.S. government, but only if:

Link to more detailed explanation and copy of the bill here.

Transcript and Summary of Webinar on Challenges Facing the OECD Antibribery Convention

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GAB’s trusty intern (NotebookLLM) finally got around to transcribing and summarizing the January webinar where three former chairs of the group charged with enforcing the OECD Antibribery Convention expressed grave concerns about it continued effectiveness.

Promotional image for a webinar titled 'Challenges Facing the OECD Anti-Bribery Convention.' Features four speakers: Martin Wolf, Drago Kos, Mark Pieth, and Danielle Goudriaan, with text overlay and a purple background.

Moderated by Financial Time’s Chief Economics Commentator Martin Wolf, the speakers highlighted several recent, disturbing developments: the U.S. retreat from vigorous enforcement of the Foreign Corrupt Practices Act, the weak anticorruption directives the European Commission has issued, and political interference in high-profile bribery cases in Italy. 

At the same time, the three — Mark Pieth, now Professor of Criminal Law, Criminal Procedure and Criminology at the University of Basel; Drago Kos, currently Interim Dean of the International Anti-Corruption Academy; and Danielle Goudriaan, presently partner at a leading Dutch law firm —  offered several paths forward.

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