In December 2021, the Biden-Harris Administration released the first-ever U.S. Strategy on Countering Corruption. The U.S. Department of State published the Implementation Plan which articulates activities it is undertaking to achieve the five pillars of the Strategy: (i) Modernizing, coordinating, and resourcing U.S. Government efforts to fight corruption, (ii) Curbing illicit finance, (iii) Holding Corrupt Actors Accountable, (iv) Preserving and strengthening the multilateral anti-corruption architecture, (v) Improving diplomatic engagement and leveraging foreign assistance resources to achieve anti-corruption policy goals.

The Rose Kross Foundation tracks the progress made towards the Strategy on Countering Corruption, provides feedback to the State Department, and publishes its own proprietary research where it identifies gaps, with a particular focus on corruption of institutions beyond national boundaries. When kleptocracy extends its transnational reach, overcomes law and regulations, and weakens support for human rights, and constitutional democracy, it strengthens its political and economic power into all realms of life. President Biden compared it to cancer. It is insidious, unseen, and it has a corrosive impact on the democratic institutions of the Western countries.

The Tools

The United States can take the several actions to promote accountability for corrupt actors around the world.  The Department of State can designate individuals pursuant to Section 7031(c) of the Department of State, Foreign Operations, and Related Programs Appropriations Act, 2023 (Div. K, P.L. 117-328), as carried forward by the Continuing Appropriations Act, 2024 (Div. A, P.L. 118-15).  The Department of the Treasury can designate individuals and entities pursuant to Executive Order (E.O.) 13818, which builds upon and implements the Global Magnitsky Human Rights Accountability Act.   

Section 7031(c) provides that in cases where there is credible information that officials of foreign governments have been involved in significant corruption or a gross violation of human rights, those individuals and their immediate family members are generally ineligible for entry into the United States and must be either publicly or privately designated.

The Rose Kross Foundation aims to participate in, and contribute to the anti-corruption government initiatives by providing focussed analysis and research in support of the US Strategy on Countering Corruption.

Nadia Zahmoul

Nadia has an Economics Undergraduate Degree from the London School of Economics and an MBA in Finance from Columbia Business School. She worked as an Equity Research Analyst at Lehman Brothers in New York. She took her Securities and Exchange Commission (SEC) Series 7 examination in 2000, a standard regulatory requirement for all incoming associates. She lived in London from 2005 to 2023, and relocated to Teton Village, Wyoming in July 2023. She launched Rose Kross Foundation in May 2024 to volunteer her background and expertise to serve the public interest. The Foundation will provide focussed research into transnational corruption. In particular, the Foundation has a special research interest in the financial markets, cryptocurrency and the use of cryptocurrency derivatives. Rose Kross Foundation aims to fill the gaps, and provide analysis and research to the Coordinator on Global Anti-Corruption on the blind spots with high social and economic cost. The Foundation aims to participate, contribute, and advocate in support of the US administration’s anti-corruption initiative.