 We've just heard that there are apparently three events today in town that are looking at this intersection between severe corruption and violence or peace building. And that's remarkable. That in and of itself represents a significant change in the amount of attention that's being paid to the role of corruption in security, both human security and sort of international security. So my name is Sarah Chase. I'm here at Carnegie Endowment. And I'm going to be sort of conducting, right? But I'd just like to spend a couple of minutes introducing the three people who are really going to be doing the speaking here. J.R. Mealy is senior policy analyst at the Enough Project, which has been working in the reduction of mass casualty space for a long time. And recently has really started to do groundbreaking work, I have to say, on how kleptocratic practices have been fueling the type of mass casualties that has been the center of their interest for a number of years. J.R. is senior policy analyst. He came to Enough from the Africa Center for Strategic Studies. And sitting to his right is Jasane and whoops, planner. And she has done a lot of on-the-ground work in both Senegal and Morocco with local news organizations, as well as reporting on both of those areas. And so she adds a very significant element in terms of how investigative reporting has a role to play in exposing what we're talking about. She went from those on-the-ground Africa experiences to CNN, where she was part of the documentary and investigations team for a number of years. Immediately to my right is Kirk Meyer, whom I've known for six or seven years. We were together in Afghanistan. Kirk Meyer is a former DEA special agent who set up the sensitive investigations unit in Afghanistan, which eventually uncovered what a number of you may have heard about, the Kabul Bank. Basically an almost billion-dollar hole in the largest private bank in Afghanistan and an unbelievable web, again sort of kleptocratic web where you had members of government who were serving themselves from Kabul Bank. It was a Ponson school, in effect, but really showing how this criminal organization that was running the Afghan government was integrated across the private sector, public sector, criminal sector, and insurgent sector. And he came to Afghanistan from a number of years in Southeast Asia, doing more specifically drug-related work, is that fair to say, in Southeast Asia? And now he's the chief compliance officer at Discover. So he will be sort of coming from the bank AML. Any money laundering? Any money laundering sanctions officer. Right. So a really good perspective on how some of the remedies that JR and Jasanth will be laying before us, what it's going to look like to actually implement some of these recommendations. So with that, why don't you guys take it away and just sketch for us what are the really significant elements of this both piece of research and recommendations that you've done. Thanks, Sarah. And thank you for hosting this event, and to the Carney Endowment for Hosting this Event, and Kirk for joining us at all of you. We're here today to launch a report called Bankrupting Kleptocracy. And our work largely focuses on East and Central Africa. In this part of the world, in several states, conflict-affected states, the state itself has been transformed from the entity that's supposed to provide social services and safeguard the rule of law into a predatory criminal enterprise that does quite the opposite. Senior government officials, top politicians, senior generals, can loot state coffers and steal natural resources, and sideline or silence anyone who gets in their way. And they can do so without facing any consequences. Oversight institutions that are supposed to stop this or bring these folks to account are marginalized, co-opted, or otherwise removed. Sometimes they're actually turned into political instruments to go after opponents. Vast majority of state institutions, in fact, are turned into political instruments to accomplish two goals, self-enrichment and self-preservation. Politics becomes a zero-sum game contest as does business. Those in power have vast economic opportunities. Those out of power do not. Peaceful paths to power are denied, and there are many violent challenges to the state itself in order to gain control over the grand prize, control over the government, and the rent-seeking opportunities that come with it. At the ENOUGH project, we're calling this phenomenon this dynamic, violent kleptocracy. The result is disastrous. As Sarah Chase and others have pointed out, kleptocracy hurts business, it spurs violence, it undermines human rights, it reduces good governance, and it provides fertile ground for the mobilization of armed groups and violent extremist organizations. A recent investigation released by this century, an investigative unit of the ENOUGH project and not in our watch, documented just how these dynamics unfold on the ground in South Sudan. We found evidence that top officials responsible for, who have command authority over forces responsible for widespread human rights violations and mass atrocities got very rich while the rest of the country suffered the consequences of civil war. They have multi-million dollar houses overseas, stakes in companies in virtually every profitable economic sector in the country, and they often receive payments from foreign companies to the tunes of tens and hundreds of thousands of dollars. They also very rarely suffer any consequences for this. So how does the international community respond? We've spent billions of dollars on peacekeeping missions that don't seem to have an end. We have peace talk after peace talk after peace agreement. And while these might be important components of a peace building operation, they really don't appear to achieve the desired result in many cases. And that's because the main players, the main stakeholders in these conflicts don't suffer any consequence for deviating from those peace agreements or undermining the rule of law. Today we're releasing a report that's gonna advocate for a new strategy that'll address that challenge, that the fundamentally distorted incentive structures of top politicians in these countries is the central part of the problem. Corruption and kleptocracy in these conflicts is the central challenge, and it needs to be the focal point of U.S. engagement in these countries. The strategy that we argue for has three main components. The first is strengthening and promoting institutions that safeguard transparency and good governance and accountability. The second is creating and protecting space for civil society in the press to scrutinize the government. And finally, creating consequences using the tools of financial pressure for those who loot and kill with immunity. So the sharper edge of the three-part approach is the last piece, the financial pressure that targets the wrongdoing and the wrongdoers. But the purpose of creating and bringing that leverage is really to create space for those other two parts, the institutions of accountability and transparency and protection for civil society. Unfortunately, there's an increasing international awareness about the importance of these things as a peace and security issue. U.S. government, the State Department in particular, has an increasing awareness of the need to address corruption issues as part of the security dynamics of a given place. There are a number of multilateral initiatives that have also represented international awareness of the importance of institutions of transparency and accountability. The U.N. sustainable development goals explicitly recognize the importance of institutions that are effective and are accountable to their people. The large multilateral open government partnership also has done a lot to advance norms of transparency and citizen participation in political decision making. For a lot of the extractives, oil, gas and mining, there have been a number of initiatives that recognize the need for government, private sector and civil society to come together around participation in decision making and transparency in the management of some of these resources. But this international momentum and recognition is really important and it needs to continue and continue to gain momentum, but it's as important to recognize the local level, the number of institutions and laws and actors in place within a country that can also add to that momentum as well. And in the cases of our countries in East and Central Africa, there are, it's important to recognize that there are these public resources in place, but they are face enormous obstacles in these heavily hijacked systems. And the Carnegie working group on security and corruption have recognized how important it is to bring a local level understanding of corruption in a given place, not just to more effectively target the problem, but also to mitigate the effect on everyone else. And when I think about the local context in some of our countries, and I focus more on Sudan and South Sudan with our other enough project staff, I think about the wealth of public resources that already exist, that have already been put in place by the people in these countries that represent the kinds of systems and forces in society that people themselves want. In South Sudan, for example, there are quite a number of laws, very good laws, not flawless, perfect laws, but a very strong legal framework. And comprehensive provisions, whether in peace agreements or the constitution or a number of laws that were enacted in 2011 and 2012 that promote transparency and accountability and participation in the management of public resources. So the support for those laws is very important, but as important as to recognize the real obstacle is a political will to implement these laws. Without some kind of leverage, all the incentives that work against the effective use of these laws, effective implementation of these laws won't work. Similarly with institutions in South Sudan, there are many good governance institutions already in place that have good mandates that are staffed by competent people of great integrity and that are trying to do good work amidst a system with all of the incentives stacked against their success. We had recently looked at three of those institutions, the country's supreme audit institution, the national audit chamber, the anti-corruption commission, and the public accounts committee of the national legislature. And these institutions are in place, they are trying to function, but they have enormous obstacles with political will of the power structure around them. So they don't receive their budget allotments. They have to do their jobs without the money and the resources that they need to do the basics. They may lack basic security in carrying out their functions. They're subject to political interference. They may do very good work, strong work, and then they push it to the next level. It may disappear into a black hole in the ministry somewhere. So again, with these institutions, the support for them is really important, but alone it's not sufficient to really address the problematic incentive structures that directly impede their ability to function. And I've spoken mostly about South Sudan, but Sudan also has in place some of these governance institutions that are really important as well. And in both Sudan and South Sudan, there are enormous public resources in the form of civil society leaders and journalists and public intellectuals and rights defenders and people with visibility into the inner workings of the difficulties of governance and have ideas and can expose problems and can facilitate a broader conversation about how to address the problems with misdirected resources and waste and diversion of resources. But here again, it's a problem of political will. They're outgunned, they're attacked, they may have their print runs confiscated. Newspapers have their newspapers taken away after they've been printed, which is financially devastating for them. Or their work might get co-opted and used to serve the preferred narrative of the system itself that is part of the problem. So in each of these cases, it's important to recognize the importance of that support for these local systems and institutions and actors and laws that are already in place and that are designed for that local context to counteract the problem. But to also recognize how easily and how quickly they're subject to the same co-optation that's part of the problematic system to begin with. And to recognize also that as long as leaders don't have stronger incentives to support these systems of accountability and transparency and these civil society groups, they'll continue to subvert them. And just to repeat the last message, building strong oversight institutions and having a solid legal framework is really crucial to address this challenge. And I think that's really been taken to heart by a lot of the stakeholders that are pushing for better governance to fight corruption and ultimately to end conflict. But a law isn't worth the paper it's written on if someone with a gun can completely ignore it with no consequences when the law becomes inconvenient. Similarly, an oversight institution is not gonna be able to fulfill its mandate if it's captured and co-opted by the people it's supposed to scrutinize or used as a political instrument against opponents. Journalists can't really do their job very well if they think that they might actually get physically hurt or killed if they do a good job and expose corruption or abuses. This is the dynamic that we're seeing time and time again in violent kleptocracies. And we're seeing this happen without any sort of consequences imposed on the people who are ultimately responsible for these abuses. We think that using tools of financial pressure that can change. But what do we mean by tools of financial pressure? It's in the title of the report. We mean policy tools that are possessed by the US government and other governments that can create financial consequences for those who are committing abuses. In the report, we discussed three or four baskets of tools. Sanctions, anti-money laundering tools, asset tracing and forfeiture tools. And perhaps the one that'll be most familiar to the vast majority of people who look at US foreign engagement on corruption, which is the Foreign Corrupt Practices Act. And this is a foundational anti-corruption mechanism. Don't get me wrong, but it does have some serious shortcomings, which I've been pointed out by Sarah and some other scholars on US strategies to counter corruption. It goes after bribe payers, but it does very little to go after bribe payers. And while it can be tweaked a little bit to maybe augment the law and go after some of the people receiving bribes, what's clear to us is that we're gonna go have, we have to go beyond the SCPA framework when we're trying to impose consequences on the people receiving bribes or otherwise looting estate assets. And fortunately, we don't need new laws to do this. We don't need new tools to do this. There are a wide range of financial tools developed to combat organized crime, to go after nuclear proliferators and other proliferators and to go after terrorist organizations. Those are some of the first tools that I was talking about. You know, sanctions are a really important one potentially. And they get a bad rap from a lot of people who follow Africa. And maybe rightly so. I mean, the way that we're imposing sanctions in Sub-Saharan Africa right now virtually guarantees value. They, you know, often are just a paper tiger. In South Sudan, for example, since the civil war began, the U.S. has threatened sanctions against the top officials in that country and in the opposition dozens of times. And never once have they imposed sanctions beyond what the United Nations has done. Sanctions often go too low. They go after mid-level officials who don't really have the authority over the decisions and the type of conduct that we're trying to stop. These people sometimes don't have bank accounts that don't travel. But then when they do, we don't really do a great job of enforcing them anyway. In our investigation in the century and the UN panel of experts also pointed this out, one of the generals under sanctions in South Sudan continued for months to have a U.S. dollar-denominated bank account in Kenya. And he continued to make transactions, an account in his own name, and he continued to have a house in Uganda where his family lived and where he traveled. That's the worst-case scenario. You place sanctions on someone, you antagonize the government, and then you don't actually impose the consequence they're supposed to impose. So in order for sanctions in any context to combat any challenge, in order for them to be effective, they need to be robustly enforced. They need to go after high-impact individuals. And importantly, they need to go after the whole network of those individuals. If you impose sanctions on someone and they hire an accountant or a lawyer or someone else who can help bust those sanctions, you're also not going after the whole part of the problem. But how can sanctions be used to fight kleptocracy and corruption? There's a couple of ways that they have been used and maybe they should become best practices. For example, stealing state assets or misappropriating state assets or engaging in corruption itself should be grounds for designation under sanctions in these contexts. That's the case in a few places like Ukraine and the Syria programs in Babway, Venezuela, but it's not standard practice. It's not the case in South Sudan, for example. You know, secondly, obstructing freedom of the press or intimidating civil society should also be grounds for destination. They're the first line of defense against corruption. We can use sanctions and there are a couple of proposals that are currently in play, the Magnitsky Act and others that would help create consequences for people who stifle the press. And finally, you know, certain things can be done like creating an automatic trigger for NFCPA conviction where the person who received the bribe is placed under sanctions. If you take a bribe or steal state assets, you shouldn't be able to use the US financial system. You shouldn't be able to buy a house here and you shouldn't be able to travel here on vacation. It's pretty simple and straightforward. But we can go beyond sanctions. There are other tools, I think there's a lot of potential in our anti-money laundering mechanisms. And there are a wide range of institutions in the US that have AML powers. Anti-money laundering itself is an attempt to stop the movement of illicit funds. The main organization that has the power to do that in the United States is an office within the Department of Treasury called the Financial Crimes Enforcement Network. And they have certain data collection and intelligence collection capabilities, some of which have been on display in the last year or so. They can issue what's called a geographic targeting order. And this happened in Manhattan and Miami where they said all cash transactions for high-end real estate require the disclosure of beneficial owners so that people can't use anonymous shell companies to buy high-end real estate and park illicit funds in the US. They also can issue what's called a 314A request under the Patriot Act, which allows them to communicate with 22,000 financial institutions and ask if they have certain types of account data or if they've maintained accounts for certain individuals that allows us to have a better picture of what's actually going on in a lot of these places. But perhaps the most potent tool, the most potent arrow in FinCen's quipper is something called special measures under Section 311 of the Patriot Act. And what this does is it allows FinCen to declare an entity, a class of transaction, a financial institution or a jurisdiction, a primary money laundering concern. And it allows FinCen to take certain special measures against that concern from collecting more information about the beneficial owners to imposing greater due diligence requirements for financial institutions doing business with them, all the way up to actually banning that entity the primary concern from having access to the US financial system. That's considered the nuclear option in terms of tools of financial pressure. It doesn't really have to be that way. It's only been used a little over a dozen times and it's only ever been used on entire jurisdiction or an entire financial institution and only the most severe special measure who's been used. We think it could be used a bit more creatively. We think, for example, you could say that the top politicians in South Sudan purchasing real estate in foreign countries, high-end real estate, represents a primary money laundering concern and that you could actually just impose greater due diligence requirements or reporting requirements on those transactions and not have the same sort of de-risking that you would have associated with a major 311 action the likes of which we've already seen. Another important anti-money laundering power happens once illicit funds transit through the United States or are parked here. We have the power to trace, seize and freeze it. There's an initiative that was formed a few years ago called the Kleptocracy Asset Recovery Initiative. It's really promising. It's the Department of Justice and FBI and a few other organizations are involved and it actually allows its mandate is to go after the proceeds of foreign corruption to find their way into the United States or transit through the U.S. financial system. Over a billion dollars in proceeds. One of our colleagues was working there for several years. She was leading the FBI's investigative efforts and they've really doubled down on this initiative. More resources and more funding and more staff have been devoted to this and it's really a promising tool that might become really relevant to the fight against corruption. I'll just close by talking about a few ways that we can sharpen the tools of financial pressure. First, there's a quote from Ambassador Daniel Freed who has had several senior roles in the U.S. government involving sanctions and financial pressure. He says sanctions are only as good as the policy they seek to advance. And that's true for every tool of financial pressure. If there's not a solid political strategy and diplomatic strategy to accompany these tools, they're not going to work. Sanctions can't become the policy. They have to support some sort of dialogue or other objectives that we're seeking to advance. The second point I'd like to make is that sanctions and any other tool of financial pressure are going to be more effective if they're imposed as part of a coalition. That's something that we've really seen in the context of Iran. But that's not always going to be possible. And if it's not possible, there are still many things the United States can do unilaterally because of the reach of the U.S. financial system. Third, we need to seek to mitigate collateral damage at any cost when we're imposing these tools of financial pressure. And what that means is making it so that these financial pressure tools don't harm our allies or innocent civilians in these contexts more than they harm the actual targets. We can go through a couple of ways that could be done in Q&A. Additionally, we think there could be better internal coordination in the U.S. government in terms of combating and when deploying these sorts of financial pressure tools, perhaps there could be established at an office of policy planning at the Department of Treasury or some other central nexus where the administration of these tools is really planned out. And finally, the office is responsible for deploying these tools and more resources. The analogy I like to use is that when we have a crisis in one part of Africa, we don't close our embassies in every single other country on the continent in order to surge resources to that particular country. But we do that with financial statecraft. Virtually all the resources going to investigations into these types of crimes are going to Iran, ISIS, North Korea, Russia, so on. And maybe for good reason. We're trying to fill some of that gap with the century, but we need to get to a place where there are sufficient resources to go after the challenges that we identify as priorities. When we impose sanctions, there need to be resources and significant financial intelligence to enforce them. And there are quite a few things that can be done and we're going to make it happen. Thank you, guys. And thanks for this incredible piece of work. Kirk, these are recommendations. How in the current landscape, and we've just heard this plea for increased resources for what amounts to civilian instruments of U.S. foreign policy, which is a pretty interesting and significant plea that we could all think about in even broader contexts. But given the current state of resources, how do you see these types of recommendations playing out? Well, I would look at it from a couple of ways. First off, I think this is an exciting time if you're someone that's interested in corruption, because as Sarah said earlier, we worked corruption in Afghanistan and it was like very few U.S. government agencies were concerned about it, but now I think almost everyone agrees that there is a link between security and corruption. And it's a lot of Africa. When we look at ISIS, the big concern is how do we deal with ISIS? ISIS, just like al-Qaeda, was based on an idea and you're not going to kill an idea with a bullet. So at some point we have to come to what's the narrative that beats their narrative? And if you look at all of these groups, the insurgent groups, you look at terrorist groups, the one narrative that's consistent across all of them is around corruption and a lot of their focus isn't the U.S. It's local. So I think the fact that now that it seems like a lot of people in the U.S. government are adopting that stance, that you can't really build a security or national security agenda unless you look at corruption involved in it, I was happy to see in the paper they had a section in there about USAID had created a program now for looking at corruption in 2015, because I can tell you prior to that they really didn't. One thing I would say, when you look at the FCPA, if you read the transcripts of the church hearings, and I encourage a lot of transcripts, but if you ever need time, have trouble sleeping, I recommend you do it. But what was interesting about church hearings that led to the FCPA, a couple things were interesting. One thing was virtually the entire federal government, the military, the state department, the intel community, the Treasury Department were opposed to the FCPA. They were adamantly opposed to it. And the reason the FCPA came around was not so much around corruption. It was a belief in the government that undermined our national security interests and it undermined it because you had businesses that were paying bribes that were doing things counter to what our interests were, our foreign policy and national security interests. So, I mean, using that as a starting point, I think is a good one, because the government can evolve in the way it thinks. And now nobody really questions the FCPA too much. It's established, though I do agree that it needs to be tightened up. Another thing, and I take this from my time with DEA and I worked a lot overseas, one thing to remember when we look at the government is one reason that there is so much focus on the financial industry and I think there needs to be a focus on the financial industry, is the government does, it's hard to believe the U.S. government has limited resources. So, I'm going to turn who's in the back, who's with Western Union now and I came from DEA. At the height of DEA, we had 5,600 agents and we had 96 overseas offices in 50 states. Pretty much that's when we talk about federal law enforcement, you see that I think Secret Service is a couple thousand, I think the FBI is like 18,000. So, you're talking about a small number of people. So, what the government has done over time is it's enlisted the financial sector and that's what I do now as a money laundering and sanctions officer to use the financial sector and the global financial system to promote and enforce our national security and foreign policy interest. And that's where these sanctions really can play, you know, changes to the sanctions. One thing that, to couple things to keep in mind which don't really come out when you read about things like OFAC sanctions, is that in theory OFAC, OFAC, why don't you just fill it out? The Office of Foreign Asset Controls, we talk about economic sanctions that you read about in the paper. In theory, they are making stand-alone decisions and in reality how that works is they float the targets around to a multitude of agencies, both law enforcement and intelligence and anybody can raise an objection and even though it doesn't have to work that way, in reality if any agency raises an objection, they generally won't pursue it. So that may explain some of the times you see things moving forward. There may be one of the organizations on that list and it's a, I can't remember everybody that saw it, but it's a pretty lengthy list has raised some kind of objection. Another thing I would say that came out of, since 9-11, the war on terror and we spoke about this yesterday when we talked about resources, is the fact that too much of the resource money has been tied to the military and not enough agencies like Treasury or others haven't asked directly for Congress to give the budgeting to deal with things like corruption or any money laundering. Everybody goes to the military. So it turns, it tends to give the military a little bit too much power in defining that agenda. Let me unpack that just a second. And what Kirk is referring to is that Treasury and Justice in particular don't tend to go lobbying Congress. State also suffers this to some extent but don't tend to go lobbying Congress for budget increases. So they have done a lot of their activities over in particular the last 15 years by getting their operating expenses from DOD. So your activities, the Afghan Threat Finance cell, was largely funded by the military effort in Afghanistan. And a lot of the police programs. What that means is that therefore the activities of Treasury and Justice in this domain are largely governed or guided by what DOD's objectives and mission and interests are. Rather than Treasury Justice DEA having their own independent ability to strategize and prioritize their efforts. Which could deflect civil society issue support or social justice support if it came counter to the military program. Other thoughts? I would say one other thing. It's not Africa specific, but the U.S. also, we just started the Finsen Justice issue, what they're calling the fifth pillar of an anti-money laundering program which is customer due diligence pillar which calls for, the U.S. has been criticized for a long time around our inability to identify beneficial owners. Now you have to identify beneficial owners that have 25% of an entity. I guess I can't emphasize how important it is that we don't just look at our programs going overseas, but look at some of our laws domestically too. We are one of the biggest overseas offshore banking centers in the world. Everybody gets all wound up about Panama papers, but if you really want to look, look at Delaware, Wyoming, and Nevada are some of the biggest producers of shell companies in the world. I know at one point we worked at DEA, we found one guy who worked out of his house in Delaware and I think he had started like 10,000 companies. And everything came to his address and it was totally legal. So besides just looking at the tools to impact what we're doing in overseas offices, I think we need to look at ourselves, what we're doing here, because in some ways we're kind of promoting these problems. And a lot of the money that's stolen overseas comes to the U.S. because it's considered the safest place to invest, especially since 2008, the financial crisis. I'd also look at things like FATCA, where we started a program to look at tax evaders. Sorry, can you, FATCA? Sorry. And now I can't remember what the acronym is. It's to identify funds where people are hiding their to avoid taxes overseas. A foreign account and for some reason right at the moment it escapes me. The OECD, the Officer of Economic Cooperation developed they looked at FATCA and they developed their own system and guidelines, but also included an information sharing component that the U.S. has refused to sign on to. So I mean I think there's elements both in what we do overseas but also things that we do domestically that we really need to think about as we move forward as a country. Because we have been criticized a great deal by different international organizations in this regard. Thank you. I'd like to emphasize just a couple of points that come out of all of that. One is that this is a Central and East Africa focus conversation. However, the way that J.A.R. described how those countries are structured applies to approximately 60 nations worldwide according to our research here at Carnegie and just to spell out what this is. What you have is at the head of a country is not a government in service of the people but an integrated network made up of private sector, public sector, criminal sector, actors who are successfully achieving their objective which is self enrichment. And these are very sophisticated networks and what they do is repurpose tools of state function to achieve this objective or other ones they deliberately hollow out. So when, for example, the anti-corruption agencies and so on are under resource, this is not an accident. They are deliberately under resource. Very often, judiciary are deliberately under resource. And that's why it's so important for the international community to come in and provide what military folks would call supporting fires for local civil society. Because while, again, the increased emphasis on civil society is great to see on the part of the U.S. government and things like that, often I feel like governments like ours are offloading their responsibility for addressing some of these issues onto the beleaguered local civil society actors who don't have the resources or ability to stand up to this very sophisticated and integrated structure. We've talked about money to the civilian instruments of foreign policy. The last point I would like to raise that hasn't been raised in this is the way that the U.S. and other western or northern countries are facilitating the type of hypocrisy that we're talking about is not limited to the activities of individual banks or real estate agents or the folks who set up shell companies, the registered agents and things like that. Very often, so USAID may have opened a corruption they are putting more people against the corruption problem but when I hold the corruption is there anybody from USAID in the room? Yeah, what unit are you from? Okay, so that's welcome. We're really glad to see you because very often what happens when I hold a corruption focused event here I get from USAID the governance people. I don't need to have this conversation with the governance people because they get it, right? We need to have this conversation with Power Africa with PEPFAR with the flagship USAID programming that often is so bent and I don't just mean USAID, I mean foreign assistance, be it whatever government it may be coming from, which very often gets so wound around the axle of its immediate objective which might be reducing HIV prevalence that they also start to say, you know what this corruption stuff later for that because first I have to address the HIV problem. Well, the fact is that just like security until you address corruption you're not going to make any sustainable headway against HIV and so the US government needs to think about not only what types of anti-corruption programming it can pay for but also how to make its civilian and military assistance less enabling of corruption in beneficiary countries and that also includes FBI, foreign direct investment. I mean what is the Commerce Department doing in terms of encouraging private sector investment into these integrated kleptocratic structures that we're talking about. So with that let's take some oh sorry go ahead. My Aleppo moment passed it's the foreign account tax compliance act so I think we're the same age, Gary and I so I apologize for that. Sir, could you please introduce yourself and you have a microphone coming to you. Thank you. My name is Ken Button I'm an economist, socializing international trade and patent litigation but in here I was very much intrigued with the concept that policy has to drive the use of financial control tools not the other way around and you've just provided some excellent description of the issue of priorities asking broadly would you please spin that out in the context of central and eastern Africa where you see US policies that are perhaps in conflict or in tension causing an inhibition on the US government's ability to really take on these anti-corruption initiatives that you've described. Go ahead you guys. Sure. Broadly speaking there's often a challenge within the US government where we hold out hope for access and continue dialogue and we we often don't want to impose consequences on these top officials because we're afraid it's going to upset some sort of political process that we hope at some point soon happens. That at the meta level I think is the most important challenge that we're facing that there are diplomats whose responsibility is to develop strong relationships with their counterparts in foreign governments that's their mandate however at some point we need to understand that the people with whom we're trying to develop relationships are at the core of the problem and they are the ones misbehaving and it's not some sort of political disagreement over the trajectory they want to take their country it has to do with control over the state and rent seating opportunities so I think the biggest and broadest way of answering that question is that US diplomats and other people at the forefront of this challenge need to acknowledge that the theft of state assets and kleptocracy is the core part of the problem that this isn't some fundamental disagreement this isn't some ideological disagreement in a lot of the context we're talking about about how best to govern a country it's not the small government versus big government it's not a values question it's about control over rent seating opportunities and if those are the people that we're trying to curry favor with and if we're relying on those sorts of actors to continue to improve governance stop abusing human rights or stop violating international humanitarian law we have a problem sometimes the challenge is that those folks need to face consequences and getting past that point with diplomats who have a three or four year tour cycle and are new to a particular country and haven't seen it act like a broken record for 10 to 15 to 20 years which is the case for some of the countries where there's going to be enough project memories can be short and people can hold out hope that maybe this particular actor can hold peace talks together maybe this particular politician is going to be maybe a little bit corrupt but not so bad we need to get past that type of thinking we need to acknowledge that kleptocracy is the problem this is a really significant question and it does change so again we're focused on this particular part of the globe but we're talking 60 to 70 countries worldwide and every country has so there are ways of talking about it either quote political tradeoffs or enabling conditions for example we did a piece of work that looked at Moldova we did a workshop in Moldova Moldova has a very similar east west kind of divide as Ukraine does and so there is a major tendency on the part of some U.S. officials to sort of say oh this leadership is quote pro western therefore we'll forgive it's et cetera et cetera and so I think it's very important to think through with respect to each particular country of interest in this regard what are the political tradeoffs because we're not trying to say all or nothing here we do understand all of us that these decisions are being made within an international political context however very often what is considered to be a tradeoff isn't really like the security versus corruption tradeoff that we were fighting all the time in Afghanistan the fact was you were getting less security by focusing less on corruption and so what we're arguing for also is a much clearer analysis of the reality of these tradeoffs so you don't just as a knee jerk in a knee jerk kind of way say oh but yeah corruption is fine but HIV is more important or but you know supporting the western faction is more important because often when you really dig down and look at it you're undermining the very objective that you think you're promoting by ignoring corruption the back with the beard that was quite the distinction out of the audience I think it's a couple of us with beards back here James Cohen thank you very much for James Cohen are you affiliated with anything Independent right now was with USIP I think a few of us were all in the room together back in June during a closed-door meeting on this kind of topic and how can we coordinate a lot more actors together and there was a lot of State Department or there was some State Department people there was usual actors from enough from Oxfam from various organizations and it was interesting that the FBI was in the room and because it was closed-door won't really go into too much else about what was said but it kind of changed the dynamic that somebody with the tools was in the room and everybody stopped talking about theoretical and went to practical and so thank you very much for this report and putting out practical tools that people can then analyze will it work or how it will work and just as you said there's ambitions for the coordination mechanisms that you have in the report how would these actually work in practice and setting up bizarre to coordinate all inter-corruption tactics and tools and policy amongst all the various departments so on that point about coordination is a struggle to get a lot of departments to coordinate period within a government if we're talking about international corruption issues it flows through many borders and many organizations how would you expand this to other countries and other organizations when in the World Bank you would also need on board would it be U.S. needs to go it alone for a bit and show success or do other countries and other organizations have to come on board with this for success I would argue that the U.S. could lead it and the examples I would say when U.S. passed the FCPA there was no other country in the world that had nanny corruption law when we passed FATCA there wasn't anything out there a bunch of the OECD countries signed up on it the fact that at this point in time about 80-85% of all money is settled each day in Manhattan is a huge I don't want to say a weapon but it's a huge power that we have we could change if we ever go to digital currency or something all this could be eroded at this point in time the way that the financial industry is based around the world it gives us a chance to be the person to drive it but we actually have to drive it and not do it sometimes here and sometimes there it has to be a true commitment do you guys have thoughts on that I'll just jump in I think we've always seen an important role for U.S. leadership in this but without the participation of regional countries and organizations it can only go so far and so that's an issue of building both the technical capacity and also the will of the regional level which may or may not actually exist to implement enforcement but that's always been an important part of our point with leadership in this and participation from the region to enforce and support that effort is pretty critical the UK did some work also at and immediately after the Cameron held a summit anti-corruption summit in May I would just add the first thing is that we are not advocating that the use of financial pressure replaces other accountability mechanisms and political strategies as a magic bullet but as a missing ingredient so working with the World Bank and working with other governments those are things that can continue to happen but as Kirk alluded the dollar is not going out of style the need to have money pass through U.S. banks is going to be in place for a long time the tools of financial pressure yes they need to be carefully used there's an analogy of sanctions to penicillin that we don't want to have them be used in such a way that the effect we're off that's important that needs to be examined in every single case but I would say that the beauty of these tools is that they already exist we're not advocating for some new behemoth legislation that will push through some new type of weapon that we've never had before and U.S. government coordination in terms of making that easier to answer to you for this particular panel I think that's probably another 10 year study that needs to take place but really what it comes down to is on a case by case basis there are different stakeholders for every single conflict but there needs to be someone at the table for any sort of discussion about the use of these tools or how to end a conflict that has on the brain is corruption or the theft of state assets a central issue and who advocates for that and says here's the menu of options that we could use and here's what we need to do to make those options effective I mean that may exist sometimes and it certainly doesn't a lot of times for a lot of these contexts for a long time there's been no one at the table saying hey how do we impose financial consequences on these people who are stealing we didn't even get to the point where we were saying hey these people are stealing lots of money and that's the problem so just to go back to that versus acknowledging it's the problem the second is putting someone at the table each time we're trying to address one of these crises that has the expertise that understands the tools and that lays out what needs to be done in order to make them work that's a really critical point right there which is to say that currently anti-corruption is ghettoized even now it's still ghettoized within the US government so it is specialized usually buried in little subgroups within the various agencies and they are not at the deputies committee or principals committee meetings when a given country is being discussed and that I think in terms of the internal coordination at the very first one potential thing to do is rather than having a cell within so here I'm going to potentially disagree with rather than having a cell within or the cell within Treasury could then report I would say national security staff there should be a fusion center that is collecting intelligence on the 60 countries creating the picture of these 60 countries how do these networks actually function and then that picture becomes part of the read ahead folder in every single deputies and principals committee meeting on that particular country so that that information is in front of the decision makers faces whenever I mean it's just there whenever they're making any type of decision to do with that country and I think that's having it at that level is important for a couple reasons and having it as an ongoing theme I'll give you an experience I had that I knew we were really you know I spent 2006 2011 in Afghanistan and but when I knew we were really in trouble was the day in 2010 I walked in and we were just starting to map out now we put cars I empower in 2010 we started mapping out his relationships and the corruption stuff and I'm looking at a big board and I'm like this is 2010 we've been here we put in power you know in 2001 nine years ago I mean what and we're just now talking about his relationships so I mean that was an eye opener to me I also think because treasury and a lot of these tools are treasury tools if you read treasuries they do a strategic document or strategic vision document for every three years the one now is to 2014 2017 and in there it says that what they do for this type of actions like the 311 measures is they try to align with the this foreign policy objectives that's how they make their alignment for the different tools that they have like 311 so it's got to be I think at the presidential 11 or at the NS NSA or NSC or it's not going to happen that one yeah Mike JJ from PACS advisory I just published two works on criminalized power structures which really are a sequel to is purely on peace processes peace implementation which relates to the presentation today comment and a question my comment has can you make the comment I'll take very quickly occasion center you know Stuart Bowen's proposal for the I think you so called US Office of Conflict Operations which was focused on interventions broadening that concept for well dealing with the 60 countries the conflict prevention as well as conflict response and intervention department at the NSC level imposed by Congress so the president can't come in willy-nilly and eliminate the planning capability that we had in PDD 56 anyway critically missing peace just one other so that my question has to do a complete thing off the money if a criminalized power structure is well the point in our work is that criminalized power structures are the leading spoilers of peace processes when you're talking about spoilers you're talking about the procracies and also insurgencies when they like the KLA when they take power they govern that's post civil liberation army for those of you who are so you're quite conversant with the phenomenon anyway cutting off the money flow is the center of gravity but your point about institutions exist, institutions exist they're subordinated, they're co-opted, they're corrupted intimidating so what can we do another really critical we need to address first of all the conventional wisdom that our exit strategy is going in strengthening the local institution so we can turn ownership over to the locals and that's the way we get out when in fact you have a topocracy you're digging the hole deep so you got to change the environment in addition to cutting off the revenue flow one other thing that is being done just like your proposals exist they have a concept when we intervene is that we either go in and replace with executive authority substitution missions or we strengthen in other words we build capacity and the problem with that I just mentioned but because we have only two that's a false dichotomy immediate option that we could pursue but we are not and that's what I call partnership but going in with international judges and local judges and prosecutors and especially somewhat like CISAC and Guatemala they're only prosecutors but and it's somewhat like in Kosovo done that formula exists in South Sudan it's not being implemented but it's in the peace agreement that's not being implemented it's also been done in car and that's pursuant not to a mandate that's imposed by the UN but to agreement among the parties I would I don't care how it comes about so your question here is why is that not being used? well yeah that's really not a question I'd like to get your reaction A to that because that makes sense as a supplement for your efforts because they would then be addressing crimes against a mandate theft of our assistance okay I think the point is clear so you guys want to fill that one thank you so just to make a big point about this you know what type of administration is set up or what type of long-term interventions happen that involve foreign assistance or foreign advisory I think there are a couple good models out there and you know the one that I'd like to point to is the governance and economic management assistance program in Liberia and really what we're talking about here just the same way financial pressure tools alter the incentive structures of people in power GMAP in Liberia sort of did the same thing and it had its flaws and I don't want to adjudicate the map here today but essentially what it was is the placement of international advisers with two mandates in ministries foreign enterprises in Liberia and different government agencies they had two mandates one was to build capacity transfer knowledge the second was to have co-signatory authority over things like you know government expenditures allocation of contracts allocation of natural resource rights and this is really frustrating for people who are trying to get something done quickly so there are a lot of complaints about it but it's also frustrating for people who are trying to steal because it adds another layer of accountability and scrutiny to the types of making that are happening in a transitional context in which for those people who followed Liberia it was a really challenging environment for anyone who was trying to build good governance structures or accountability or fight corruption but what you're doing is you're stemming the flow of illicit money at least a little bit out of the main rent seeking organizations where rent seeking opportunities exist that worked in Liberia there's a long legacy of US engagement in Liberia that maybe after a very tough period of negotiations that was pushed through that's not necessarily possible in every context I mean ultimately in order to have something like this be legitimate you really have to have local buying in South Sudan for example there's a lot of kind of local support for the hybrid court which is mandated by the peace agreement it would be South Sudanese judges and judges from the region from I think the AU but not necessarily the top level support for that happening right now even that is a struggle I mean there is the very famous op-ed that South Sudan needs peace not trials or something like that and that was obviously controversial but you know really that sort of arranged what is needed not just for mass atrocities and human rights violations but for the governance of economic institutions in a transitional context where there's been violent kleptocracy I think that there is a real nascent conversation that has gotten a little bit eclipsed by the current conditions in South Sudan but that is very much along the lines of what sort of international oversight structure might be in order to stem and staunch the outflows of public resources and better bring public financial management under control and there of course concerns on the part of South Sudanese government for sovereignty issues but nonetheless this concern of if government if external aid is going to be coming into this country and it's going to be misdirected so massively for private or wasteful or militaristic purposes what sort of oversight structure and I think that the debate is open for the particular modalities of that how does it actually look there some risks and pitfalls all the way around for the dual key co-signatory approach and some real concerns about who that punishes who takes on that responsibility and answers for problems that continue even as the spending tries to come under control but it's very interesting conversation and one that we're following closely and I think that there's a lot of space for discussion on how that kind of oversight mechanism best fits the local conditions and works with the local forces in that particular context can I say one quick thing another thing I think and it's not a popular thing to say nowadays but I think in this area the government needs to grow I think in anti-corruption far too much of it's been contracted out and it's almost like a check the box to satisfy congress oh yeah we're doing anti-corruption I mean I think there are people that work for private companies that probably do a good job but overall I would say that the people that we're fielding probably really aren't the people that should be there or that are going to have a create a sustainable program either where they're going to learn say they say they were even good they did as a contractor when they move on they move on there's no that institutional knowledge that remains that say we went to Sudan and now we're going to take what we learned from there to somewhere else it disappears with the next contract so I think there has to be professionals that are trained to manage and to implement these types of program just so you all know it is a few minutes after two I'm going to take several more questions three I'm going to take a few more questions but if anybody does need to leave at the top of the hour we understand that sir my name is Gordon and I'm from South Sudan Embassy so my question is directly to the thesis you guys are advancing on the issues of South Sudan because I remember last year the chief of staff of the president the executive director and the other 16 officials were arrested and persecuted some of them are given lives because of corruption that one is not being mentioned because they were saying that oh there's no political will but if there is no political will how would the chief of staff of the president be arrested and sentenced to 30 years is one thing the central report I read it I think it's good there is one of the authors there is a guy called they mention a guy called Luol Malong that is a young tycoon but Luol Malong doesn't have a bicycle even a bank account doesn't have that because when I read if you get wrong Luol Malong not being a millionaire or a tycoon then you would have a lot of problems it's good that the USID guys here because before the independence of the south most of the institution the south were built by the Troika United States involved and then Norwegian and then the World Bank and the MF I think they took Ethiopian, Ugandan, Tanzanian and South African to train the people in the south to build the institutions so this western country were involved trying to build the capacity of the south for the independence so I believe the United States spent around 350 million training the SPL the USID guy would be here to testify on that so now my question is if you talk about kleptocracy in the south how will you exclude the United States government or the European Union or the World Bank or the MF that built the institution in the south but there were the very people who built the institution in the south in terms of houses I know that when the CPA was signed there was a package which was part of the CPA agreement and before the death of Dr. John 300 million dollars were advanced to him before going to Khartoum to give it to SPLA generals and that one if you ask the State Department they will tell you that is the money they used to buy the houses the reason why it was put like that the idea was that okay to strengthen the position of Dr. John and to stabilize all his control within his army there was no mentioning in the central report that there was some sort of the money advanced to Dr. John so this is because I'm trying to question the thesis that you are advancing thank you great question the first part I think you said so there were essentially two or three pieces to that so the first was that there were 16 people arrested for corruption last year including a senior official the second was that a young man named Lawrence Llamalong Jr. who was mentioned in the report you're saying he doesn't have the level of assets we did and third you're saying there was an abundance of money provided to the senior government officials and generals more than a decade ago when that conference a peace agreement was signed the second part arresting someone for corruption does not mean that there is an effective system for countering corruption in the country you take a look at the People's Republic of China for now there's a really aggressive anti-corruption campaign that's been happening for a while when you talk to a sinologist a lot of folks will ask the same question I haven't seen many of Xi Jinping's allies fall in that anti-corruption drive so a lot of times anti-corruption itself can be used as a pretext for going after political opponents that happens I'm not going to speak to specific instances in which South Sudanese folks have been arrested whether they were corrupt or not the fact of the matter is we found significant evidence of conduct that's pretty reprehensible and what we would hope is that the evidence that we put forward would be taken very seriously and the South Sudanese government and other governments would begin to take action to investigate very thoroughly all the specific claims that we have advanced with an objective mind in order to hold those folks accountable and not a knee-jerk reaction to combat what we're saying in order to dismiss reports that's based on documentary evidence and two years of reporting the second notion the young tycoon launched the wall among your junior posted like a dozen photos of himself flying in first class all of which say smart boy for life flying first class it's somebody who I called on the phone to solicit comment I said I'm an investigator for the century you know I'd like to get your comment on a few mining companies in which you're involved his response to me was oh yeah he starts pitching me on a mining deal he says oh yeah when we do mining my dad and the president will be involved his dad is the SPLHE for staff who we found has a $2 million house in Nairobi and several houses in Uganda I mean dismissing individual accusations that we made first of all which are based on solid evidence doesn't dismiss the massive problem that is corruption and kleptocracy in South Sudan it's a really serious challenge that needs to be addressed not just by folks in DC but in South Sudan themselves and finally just on the notion that you know hundreds of millions of dollars were transferred to top generals I think it's important that those assets are declared searchable I think it's important that you can go online and find out the exact wealth of a senior politician in a country where corruption is raised as such a significant problem one of the things we found that startled me so much was we found that the 12 year old son of Sal Bakir holds a stake in a holding company that was created earlier this year you know we found evidence that family members the vice president top generals hold stakes in virtually every profitable economic sector I mean these are not things that you could google and find out these are not things that the average South Sudanese person could understand you know we know that state contracts have gone to some of these companies I mean it's really even if in many of these cases the laws aren't being broken I think the public has a right to know and to scrutinize and currently that's not possible so better systems need to be developed the press needs to be empowered and protected to actually go after and scrutinize some of these deals there was a newspaper in South Sudan that published the century report right after it came out they republished our content they were shut down the next day that's not acceptable that's not acceptable political discourse when you're talking about corruption if in your country talking about corruption means that you are silenced immediately there is a structural fundamental problem and that needs to be addressed and the people that are responsible for silencing these folks they need to face consequences I want to put anything else in I'm not sure how I follow that but I wanted to pick up on the piece that you mentioned about the role and the influence of the Troika and the institutions and I think I have done some work in my past before I came to enough that really wrestled with some of these questions of legal provisions and governance provisions and institutions mandates for for rule of law institutions in South Sudan specifically and I know that there was a great effort in the projects and the work that I was doing to collect collect information about some of these particular questions that lawmakers in South Sudan were facing and to put in front of them information that would help South Sudanese lawmakers design their own institutions that would be suitable for the local context not externally imposed institutions and legal provisions but institutions that could benefit from a collection of information and best practice broadly speaking and I think that one of the reasons that South Sudan's laws and institutions are so well regarded in many cases is because they have incorporated lessons in best practice but that they were adapted by South Sudanese lawmakers for the particular context that they faced and so I think that there was certainly that effort to support but put lawmakers themselves in the lead the issue that I came back to and I have hardly the first to say it but it's not the laws themselves that are on the books, it's the implementation of the very good laws that are there and I think that gets back to all of the political will and the systemic structural conditions that are stacked against implementation of the strong laws that were crafted very carefully with South Sudanese leaders in the front seat I think there is a fair point also about the role again in particular of international development financial institutions which dovetails with what I said earlier about USAID the World Bank I think is becoming a little bit more conscious about how some of its lending may be facilitating and enabling kleptocratic practices but it's a slow ride and the World Bank is still kind of allergic to the word corruption IMF which has done a lot of harm in this regard over previous decades is beginning to get a little bit more conscious and focused here but international financial sorry, international development finance is a really interesting can of worms because as I've been discovering recently you can have a government puts development dollars or name your currency into its development bank with the objective being to quote leverage more money because it's leveraging the private sector etc etc I've just been tracing one particular tiny little stream and I've found it's a country that's not the United States that's easier to track than the United States its development bank put an undisclosed amount of money into a fund an infrastructure fund in which there are other investors etc etc what you discover is that this money is almost being layered almost the same way that shell companies are layering money and you can't trace it anymore and at every layer there's less and less oversight in terms of whether the project being financed by this money is in fact achieving the development objectives that the initial let's say the foreign ministry or whatever it might be of the government had set out and this is a really big problem and I think the notion particularly in the types of countries that we're talking about the notion that more money put against the problem is necessarily better is patently false we have seen this in our in development situations all around the world and most particularly in Afghanistan and Iraq where the resources were almost unlimited and it did not produce more peace or more development so I do think the world bank point was a particularly good one more and then we will all be here if anyone wants to come up afterwards did yes there's we have another beard also in the back hi I'm Zach Lubellefeld I'm a graduate student at the Maxwell School at Syracuse University what are you doing this far from home I'm here for the semester so and it's much warmer the question I have relates to how currently the governments in Central and Eastern Africa the clotocracy isn't a disease attacking the system so to speak so much as the system itself and so we have a situation like this where where the clotocracy are the structures in place and there's no or very little political structures of civil society from the outside of them at the end result of all these let's say that at some point in the future the use of financial tools like these they discussed today along with other message actually bring an end to this corruption change the structures what can be done play what can be done after that to ensure that there's not that that the vacuum that would definitely be filled does not lead to just another cycle of the of the of the political violence and a return to the rent-seeking governments that exists currently that's a great question which do you mind if I just take a broader whack which is this is one of the most significant questions kind of worldwide so taking us out for a second of this geographical context let's look at the transition the anti-corruption transition countries that we have in the world right now including Tunisia not to mention Egypt, Libya you know etc but let's take Tunisia let's take Guatemala where the seasig which has been mentioned already led to you know the fall of a government let's take Brazil let's take Ukraine let's take Nigeria where we didn't have an external thing but we had a kind of uprising of the population that voted a very corrupt government out of power I think in only one of those cases do we have potentially yet a really serious resistance to the recombination of new kleptocratic networks and that one case is Ukraine and it's so my initial answer is number one watch Ukraine and see what they are doing to prevent precisely this they've been through it once before they had an anti-corruption revolution and so they're a little bit vaccinated and they're working pretty hard the second one I would urge you to look at that's really interesting and is slightly under the radar at the moment is Honduras so in the wake of seasig in Guatemala the Honduran stood up got in the streets and said we want a seasig so they have something called the Maxi which has been it's now at the end of six months or it's approximately at the six months point and what's really interesting about Maxi it has slightly less prosecutorial autonomy than the seasig did or does and a lot of people saw that as a weakness including a lot of Hondurans at the moment see this as a weakness because it doesn't have quite as much ability to initiate prosecutions on its own on the other hand it has a much more significant authority to get involved in the types of institutional reforms that could prevent a new kleptocratic network from taking the place of the old once the prosecutions take place and that includes for example there in the process of developing a campaign finance law wouldn't that be nice in the United States of America and Maxi is involved in that they can look at the criminal code and business law to look at reforms and business law that would prevent some of the kinds of sweetheart deals that currently tie the public and private sector in Honduras's kleptocratic network and so I think there are some tentative experiments that are looking to solve the problem that you're talking about some notable failures are Tunisia where in my view although it's peaceful it is a peaceful restoration Egypt is even worse it's a violent restoration and Nigeria is not at all clear at the moment I would add that I think that this is why I spent so much time talking about the importance of really recognizing and acknowledging those local public resources that are already in place even in these countries that have been overtaken by a kleptocratic system there are civil society actors and institutions and laws that are the entry points they are the locally designed systems and processes to counteract the problem they're just outgunned so throwing support behind those publicly minded institutions supporting the people who have interesting policy proposals that are in the broad interest of public intellectuals that are really trying their best to pick apart and analyze the crazy budget exercises that are happening in some of these governments finding and supporting those people and those institutions that are already there but that have been weakened I think is an important part of the puzzle toward preventing some kind of a vacuum where the problem will just be recreated more support for the people who are already working in the public interest and are able to represent and advocate for broad interests instead of narrow interests Kirk before we wind up do you have any just sort of closing thoughts? I would say one thing that I'm hopeful for is that we'll enact the global Magnitsky Accountability Act because it'll actually make tools focused on anti-corruption and I say that because and you have this in your paper the fact that a lot of times these tools are part of sanctions but they're like they're a sub part of it and a lot of times they're not enforced or really implemented this would highlight it and make it more powerful because it would be the single focus and it would protect has the potential to protect the civil society people and the press I think you have to have a strong press to get stuff out I almost think sometimes in these areas we'd be better off handing people cell phones in the millions so that people could self-report stuff on social media more than we would just hand out money it might actually benefit us in the long run so all of you who are US citizens please write to your senator actually on global Magnitsky it's been resolved for a little while judiciary committee also and it really makes a difference people think there's no constituency in the US for this type of issue and so it's important to show that that's not the case thank you all for coming and have a great rest of your afternoon