Just two weeks into President Donald Trump's second term, then-Attorney General Pam Bondi issued a series of memoranda that reshaped priorities at the Department of Justice, according to Casey Michel, writing for The New Republic. These memos are neither laws nor formal regulations; rather, they reorient DOJ enforcement focus, effectively dismantling key anti-bribery and anti-kleptocracy frameworks built over decades — some predating Trump's own birth in 1946. Because the changes were implemented through executive directives rather than legislative repeal, they could in principle be reversed by a future administration, but for now represent a sweeping shift in federal anti-corruption posture.

The first target was the Foreign Agents Registration Act (FARA). Although FARA remains a statute passed by Congress, Bondi directed that enforcement would center exclusively on lobbying offenses deemed "similar to more traditional espionage."

"For decades, FARA was itself a backwater, largely unenforced and almost entirely overlooked," Michel wrote. "That disuse allowed the foreign lobbying industry — which now comprised not just traditional lobbying shops, but also PR professionals, consultancies, white-shoe law firms, think tanks, and many more — to blossom into a multibillion-dollar behemoth, flipping into the go-to tool for foreign dictatorships looking to tilt American policy however they wanted."

Under Bondi, enforcement grew even more permissive. Critics pointed out that the DOJ's emphasis on crimes "similar to more traditional espionage" made no sense, as the report noted: "FARA has nothing to do with spying." The result was that, under Bondi, FARA was effectively dead.

Bondi then moved to eliminate the FBI's Foreign Influence Task Force. Notably, the task force was originally created during Trump's first term and had become, as described in the report, the "U.S.'s leading tool for tracking and tracing foreign influence campaigns around the country, dedicated to dismantling infiltration campaigns out of places like Russia, China, Iran, Venezuela and more."

Next came the dismantling of the Kleptocracy Asset Recovery Initiative, established in 2010 to disrupt networks channeling illicit funds into the United States. The program recovered only millions — not billions — in money "pilfered around the world," but it did facilitate the return of looted assets to countries including Nigeria, Malaysia, and Uzbekistan.

Also eliminated was KleptoCapture, a program created in response to sanctions on Russia following its invasion of Ukraine. The initiative enabled the U.S. to freeze or seize assets within its borders when those holdings were tied to "illicit" means, including connections to the Kremlin. Russian oligarchs had already faced similar asset actions in other countries.

All of these changes were carried out "in a single day," effectively "kneecapp[ing] its most successful and most prominent counter-kleptocracy tools," Michel reported.

The changes did not stop there. Trump subsequently revoked enforcement of the Foreign Corrupt Practices Act (FCPA) through an executive order. Enacted in 1977 in the aftermath of the Watergate scandal, the FCPA had made the United States the world's most aggressive enforcer of anti-bribery laws and a model for the OECD Anti-Bribery Convention, which Washington spent decades urging other nations to adopt. The president argued the law was an impediment to "American economic competitiveness" and restricted American companies from engaging in "routine business practices in other nations." Michel characterized the rationale as "a handy euphemism for bribery."

The FCPA's rollback put "foreign corruption ... back on the table," according to the report. "Kleptocratic regimes and crooked American businessmen around the world rejoiced, knowing they wouldn't have to worry about pesky prosecutions anymore," Michel wrote. "One of the greatest post-Watergate reforms was now dead, for all to see."

In 2021, the United States established its first-ever shell company registry under the Corporate Transparency Act, designed to prevent oligarchs from using corporate structures to conceal ownership. By March 2025, Trump had eliminated that registry as well.

In its place, the administration introduced Trump's so-called "golden visa" program, which permits individuals to purchase U.S. citizenship. As Michel concluded: "Kleptocrats couldn't have asked for more."