image description

Advocacy Work

The Coalition for Integrity engages in a variety of forms of advocacy in addition to the articles and blog posts we publish. We meet with members of government and international institutions to discuss our policy recommendations on subjects of interest to us. We also write letters, policy papers, and press releases, which are found below.

October 25, 2022 – 80 organizations, including Coalition for Integrity, write to Congress in support of the ENABLERS Act in the National Defense Authorization Act. Read the letter here.

June 24, 2022 – Coalition for Integrity’s letter to the U.S. Senate Committee on Appropriations’ Subcommittee on Financial Services and General Government to express our support for and encourage the Subcommittee to approve increased appropriations for the Financial Crimes Enforcement Network (FinCEN) in line with the President’s budget request for the 2023 fiscal year. Read the letter here.

February 21, 2022 – Coalition for Integrity’s comments to the Financial Crimes Enforcement Network (FinCEN) of the Treasury Department on a proposed rule that would address the vulnerability of the U.S. real estate market to money laundering and other illicit activity. Read the comments here.

February 15, 2022, the Coalition for Integrity and other civil society organizations signed a letter urging Senate leaders to allow the full Senate to consider and vote on pending nominations to all three vacancies on the Merit Systems Protection Board (MSPB).  Read the full letter here.

February 7, 2022 – Coalition for Integrity’s comments on notice of proposed rulemaking (NPRM) to implement the beneficial ownership reporting requirements in the Corporate Transparency Act (CTA), submitted on February 7, 2022. Read the comments here.

May 3, 2021 – Coalition for Integrity’s comments to Financial Crimes Enforcement Network’s (FinCEN) advanced notice of proposed rulemaking (ANPR) to implement the beneficial ownership reporting requirements in the Corporate Transparency Act. Read the comments here.

April 1, 2020 – Coalition for Integrity is pleased to be one of the 265 organizations supporting strengthened whistleblower protections. Read the letter here.

August 4, 2020 – Coalition for Integrity provided comments to the Vermont State Ethics Commission as they worked on a draft Code of Ethics. Vermont scored 37% and ranked 40th in the 2018 S.W.A.M.P. Index, largely due to the ethics agency’s lack of sanctioning authority. Read our letter here.

July 10, 2020- Coalition for Integrity joins 80 organizations supporting CoST (– the Infrastructure Transparency Initiative), Accountability Lab, and Hivos to call for continued support of transparency and accountability initiatives in Covid-19 response efforts. Read the letter here.

July 9, 2020-  Coalition for Integrity joins 23 organizations to call on Secretary of State Mike Pompeo and Secretary of the Treasury Steven Mnuchin to utilize Global Magnitsky sanctions to fight against corruption amidst coronavirus response efforts. Read the letter here.

June 29, 2020 – Coalition for Integrity urges Senate leaders to advance the Anti-Money Laundering Act of 2020. Read the letter here.

April 13, 2020 – Coalition for Integrity joins nine other nonprofits in urging Congress to adopt anti-corruption initiatives in their response to the COVID-19 pandemic. Read more here.

January 21, 2020 – Coalition for Integrity sent a letter to Director of National Economic Council Larry Kudlow emphasizing support for the Foreign Corrupt Practices Act and emphasizing that now is not the time to send the signal that the U.S. is reconsidering or might even weaken the FCPA.  Rather, now is the time to  push for strong and consistent enforcement of the OECD Anti-Bribery Convention and press major economic competitors such as China and India to become signatories to and enforce the obligations of the OECD Anti-Bribery Convention. Read more here.

June 19, 2019 – Coalition for Integrity’s letter to the Committee on State Government in Pennsylvania’s General Assembly providing comments on House Bill 1291 which seeks to enact better gift rules. Pennsylvania received a score of 51% and ranked 28 in the S.W.A.M.P. Index. The major reason for this low score was the State’s failure to effectively prohibit acceptance of gifts, particularly by legislators, and lack of transparency in reporting gifts. House Bill 1291 represents a positive step that would increase Pennsylvania’s score in the S.W.A.M.P. Index to approximately ­­62 out of 100. Please read our letter here.

May 6, 2019 – The Coalition for Integrity is proud to stand with over a 100 organizations in calling for transparency into the beneficial ownership of anonymous shell companies.  Read letter here

March 1, 2019 – Legislators in New Mexico are drafting legislation to create an independent ethics commission after a constitutional amendment passed this November.  New Mexico received a score of 36 out of 100 in Coalition for Integrity’s States With Anti-corruption Measures for Public Officials (S.W.A.M.P. Index). This score reflects the current lack of an independent ethics agency in New Mexico.  Coalition for Integrity reviewed the pending legislation and provided our comments to guide the process and recommend best practices.  We reached out to the House and Senate Leadership and Senate Committee Chairs.  You can read our letter here

February 26, 2019 – Legislators in North Dakota are in the process of reviewing legislation to create an independent ethics commission after a ballot measure passed this November.  North Dakota was last in Coalition for Integrity’s S.W.A.M.P. Index. Coalition for Integrity reviewed the pending legislation and provided our comments to guide the process and recommend best practices.  You can read our letters to the House Ethics Committee here and Senate Ethics Committee here.

August 6, 2018 – The U.S. needs to advance a positive message at the G20 Summit which emphasizes the importance of all G20 countries acting to combat corruption.  Strong implementation and enforcement of foreign bribery laws has also been included in the G20 commitments at least since 2010. The 2018 Leaders’ Summit presents an important opportunity to make progress on a longstanding G20 commitment. We at the Coalition of Integrity have written to President Trump calling for consistent enforcement of foreign bribery laws by all G20 countries.  The United States Chamber of Commerce, the American Federation of Labor and Congress of Industrial Organizations, United States Council for International Business, National Foreign Trade Council and the International Corporate Accountability Roundtable have also signed the letter along with us. Read our letter here

June 14, 2018 – The Coalition for Integrity renewed the call for The Counter Terrorism and Illicit Finance Act (H.R. 6068), currently being considered by the House Financial Services Committee, to address meaningfully issues of beneficial ownership transparency. Read more

May 25, 2018 – C4I urged the Federal Elections Commission to expand the reach of its political disclaimer requirements to political ads on all internet-based media. Read more

December 6, 2017 – We sent a letter to the leadership of the House Financial Services Committee advocating key principles on beneficial ownership transparency in the pending Counter Terrorism and Illicit Finance Act.

October 20, 2017 – We joined with 26 other organizations to urge Senators to support the Honest Ads Act. Read more

June 28, 2017 – The Coalition for Integrity joined several other civil society organizations in sending a letter to Representatives Maloney, King, Royce, Moore, and Waters expressing support for the bipartisan Corporate Transparency Act (H.R. 3089), which would require companies to disclose information about the real people who own or control them (often called the “beneficial owners”) at the time they are created. A letter was also sent to Senators Whitehouse, Grassley, and Feinstein to express support for the Senate version of the bill, the bipartisan True Incorporation Transparency for Law Enforcement (TITLE) Act (S. 1454).

June 15, 2017 – Coalition for Integrity Statement on the Conflicts of Interests that continue to plague the White House. Read more

Jan 31, 2017 – We joined several other civil society organizations in sending a letter to Speaker Ryan, Minority Leader Pelosi, Chairman Hensarling and Ranking Member Waters urging them to support the Cardin-Lugar Anti-Corruption rule and vote no on H.J. Resolution 41. Read more

Jan 31, 2017 – We joined several other civil society organizations in sending a letter to Majority Leader McConnell, Minority Leader Schumer, Chairman Crapo and Ranking Member Brown urging them to support the Cardin-Lugar Anti-Corruption rule and vote no on S.J. Resolution 9.  Read more

November 21, 2016 – TI-USA Issues Key Recommendations for New Administration to Avoid Conflicts of Interest. Read more

November 9, 2016 – TI-USA urges President-elect Trump to establish a transparent organization and among other things limit the role of federal lobbyists in developing his administration’s policy agenda. Read more

May 12, 2016 – The U.S. government released its action plan to tackle corruption at the international U.K Anti-Corruption Summit hosted by David Cameron. Transparency International-USA points out that more action is needed to tackle anonymous companies and the flow of corrupt proceeds into the U.S. Read More

May 06, 2016 – Treasury issues new rules on customer due diligence: Transparency International-USA points out that gaps remain and more action is needed. Read More

April 28. 2016 – TI-USA urges the Administration to include commitments on beneficial ownership transparency and contract transparency in federal procurement in the third Open Government Partnership National Action Plan. Read More

April 28, 2016 – TI-USA along with 22 other organizations urges the U.S. Department of Treasury and Office of Management and Budget (OMB) to embed beneficial ownership transparency in federal procurement through the implementation of the Digital Accountability and Transparency Act of 2014 (DATA Act). Read More

March 21, 2016 – TI-USA calls for greater transparency by the Department of Defense on all security assistance programs. Read More

February 16, 2016 – TI-USA submits comments to the Securities and Exchange Commission answering specific questions posed by the SEC about the rule being drafted to implement Section 1504 of Dodd Frank. Read More

February 2, 2016 – TI-USA issues a press release welcoming the introduction of legislation promoting beneficial ownership transparency. Read More

December 8, 2015 – TI-USA sends a letter to the Securities and Exchange Commission containing four recommendations for the rule being drafted implementing Section 1504 of Dodd Frank. Read More

October 2, 2015 – TI-USA send a letter to the Securities and Exchange Commission urging prompt action in the release of a rule implementing Section 1504 of Dodd-Frank. Read More

June 5, 2015 – TI-USA writes a letter signed by 106 other civil society organizations to the World Bank President and Executive Directors urging the collection and publication of the beneficial ownership information of bidders on Bank-financed procurements. Read More

April 22, 2015 – TI-USA issues a press release calling for full disclosure of the sources of political spending in the United States. Read More

March 10, 2015 – TI-USA writes a letter signed by 17 civil society organizations to the Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) seeking action to close the loopholes in the current legal framework that allow corrupt individuals to launder money in the United States through anonymous real estate transactions. Read More

February 20, 2015 – TI-USA provides the World Bank with policy recommendations for improving public participation in the project design and implementation process. Read More

December 10, 2014 – TI-USA provides the World Bank with policy recommendations for making its procurement policies more transparent and less vulnerable to corruption. Read More

October 2, 2014 – TI-USA writes to FinCEN urging it to strengthen and finalize the rules proposed in 2014 that require financial institutions to carry out appropriate due diligence to identify and verify the ultimate beneficial owners of legal entity customers. Read More

June 9, 2014 – TI-USA writes to the Chairwoman of the Securities and Exchange Commission urging her issue a rule under Section 1504 of the Dodd-Frank Act requiring U.S.-listed companies to publicly report the project-level payments they make to all governments. Read More

March 21, 2014 – TI-USA writes to the United States Trade Representative urging the inclusion of strong anti-corruption and legal and regulatory transparency requirements in the Trans-Pacific Partnership and Transatlantic Trade and Investment Partnership. Read More

October 30, 2013 – TI-USA provides the World Bank with policy recommendations for improving its sanctions system through which investigates and adjudicates cases of corruption and fraud by contractors on Bank-financed procurements. Read More

July 18, 2013 – TI-USA writes to Senator Levin, and Representatives Maloney and Waters to express support for the introduction of legislation that promotes transparency in beneficial owners of corporations and limited liability companies. Read More

July 1, 2013 – TI-USA writes to the United States Trade Representative urging the inclusion of strong anti-corruption and legal and regulatory transparency requirements in the Transatlantic Trade and Investment Partnership and providing suggested language for anti-corruption and transparency provisions. Read More

February 16, 2012 – TI-USA provides the World Bank with policy recommendations for strengthening its governance and anti-corruption policies. Read More

January 12, 2012 – TI-USA writes a letter signed by 32 civil society organizations to every member of the U.S. House of Representatives and U.S. Senate defending the Foreign Corrupt Practices Act (FCPA) against attempts to weaken it. Read More