The first evidence of the sledgehammer the new Trump administration would take to America’s anti-corruption policies came just two weeks into his second term. The new attorney general, Pam Bondi, unveiled a series of memos outlining the Department of Justice’s new priorities. Unsurprisingly, in a White House overseen by the first white-collar criminal ever elected to the presidency, Bondi’s department revealed that it was decimating many of the key planks of the anti-bribery, anti-kleptocracy regime it had built out over the years—some of which were on the books since before Trump was even born.
The first on Bondi’s chopping block was a statute known as the Foreign Agents Registration Act (FARA). First enacted in the late 1930s, FARA was a relatively simple piece of regulation, requiring transparency among Americans lobbying on behalf of foreign regimes. FARA didn’t block the practice; thanks to First Amendment protections, Americans had wide leeway when it came to who they could lobby for—who they could spin, who they could whitewash, who they could open doors in Washington and around the country for.
For decades, FARA was itself a backwater, largely unenforced and almost entirely overlooked. 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. Following Trump’s first election, which elevated foreign lobbyists to more political power than they’d ever seen prior, FARA saw new life. Prosecutors went after foreign lobbyist after foreign lobbyist, from Trump’s campaign director to his national security adviser to many more, landing guilty pleas or outright convictions, and forcing much of the industry into the light for the first time.
Nor was this a partisan pursuit; in 2024, then-Senator Bob Menendez was found guilty for, among other things, secretly moonlighting as an agent of the military dictatorship in Egypt—for “conspiring to act as a foreign agent” on behalf of Cairo, lobbying his congressional colleagues and ghost-writing for his dictator clients, all in return for gold bars that Menendez hid around his house.
By the early 2020s, FARA was finally relevant, arguably for the first time ever. And then Bondi came in, and announced those days were done. FARA would still remain on the books, but Bondi—who herself had once worked as a foreign lobbyist for the theocratic dictatorship in Qatar—announced that it would focus solely on lobbying crimes that were “similar to more traditional espionage.” It’s unclear what Bondi was talking about; not only does the US already have separate legislation targeting espionage, but FARA has nothing to do with spying. It is instead meant to specifically shine light on the subterranean lobbying networks operating in the shadows around Washington—how foreign regimes, foreign oligarchs, and many others push for their preferred policies, from lifting sanctions to ending corruption investigations to even launching wars.
But now, thanks to Trump, it was a nonstarter. Where FARA had once been the lodestar for foreign lobbying legislation around the world, Bondi announced that it was now effectively dead—and all that information and transparency that Americans once had access to would be no more.
In another memo, Bondi declared that the Trump administration was also dissolving another prong of the US’s fight against kleptocracy: the FBI’s Foreign Influence Task Force. First created in 2017—during Trump’s first term, ironically—the group had quickly transformed into the US’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. Given the explosion in interference campaigns in recent years, the FBI’s task force had only grown in import since its inception. Bondi announced its elimination, killing off the US’s only body dedicated to investigating foreign influence.
Next on the chopping block was the Kleptocracy Asset Recovery Initiative. Inaugurated in 2010, this was a body dedicated to freezing, seizing, and repatriating assets linked to dirty money networks around the world, who often plowed their illicit wealth directly into the US. While this task force was always fighting an uphill battle—the millions it returned hardly compared to the billions (or more) pilfered around the world—it nonetheless stood as a testament to the US’s public willingness to go after these networks. In Nigeria, in Malaysia, in Uzbekistan—in country after country, this body helped return some of the looted wealth, and helped restore some of the US’s mangled credibility in the fight against dirty money. And now, with the stroke of a pen, it was gone.
Bondi’s scythe continued on. She announced the US was also eliminating another task force dedicated specifically to oligarchs’ assets. Known as KleptoCapture, the relatively new initiative grew out of Russia’s expanded invasion of Ukraine in 2022, and out of the realization that oligarchs in Russia and elsewhere were simply prongs of kleptocratic governments across the globe. Yachts, mansions, luxury jets, priceless artwork, armadas of high-end automobiles—it was all fair game for KleptoCapture. If they could identify the proceeds of illicit wealth—especially linked to those closest to the Kremlin—they could swipe it, and help close off the American economy to Russian influence that much further. That was the case, at least, until early 2025, when the Trump administration destroyed it outright.
These are all a jumble of names and acronyms, neologisms unfamiliar to those outside Washington. But pulling back, one thing from Bondi’s memos was clear: In a single day, just a few weeks into Trump’s new administration, the US had eliminated or kneecapped its most successful and most prominent counter-kleptocracy tools. Years of progress had been undone. Decades of legislation had been left for dead. The American economy was suddenly opening itself up for illicit wealth, for foreign influence, for kleptocratic regimes writ large in a way it never had prior. Oligarchs around the world watched how their counterparts in America had pried open a White House, and suddenly realized that they could do the same. That they could join in the fun—join in this feast of making white-collar crime great again.
And the best was yet to come.
As the dust settled on Bondi’s memos, Trump himself took up his pen—quite literally. Busy shaking down American media outfits, strong-arming American universities, and authoring the most authoritarian administration the country had seen at least since the days of Richard Nixon, Trump turned to dismantling America’s remaining anti-corruption credentials. Where he’d previously danced around and badmouthed America’s anti-kleptocracy toolkit, now he would destroy it wholesale.
His first target was the Foreign Corrupt Practices Act (FCPA), which had itself been a direct outgrowth of Nixon’s rank corruption. Trump openly described the FCPA, the very bedrock of America’s anti-corruption efforts, as a “horrible law.” To Trump, the FCPA wrongly blocked American companies from engaging in the kind of routine, high-level bribery firms elsewhere practiced. Rather than a shield that protected American corporations from being themselves targeted by rapacious regimes, and rather than a tool that helped starve dictatorships of much-needed cash, Trump thought the FCPA was a “horror show” for the US.
In an executive order, Trump garroted the FCPA entirely. He announced that all enforcement of the legislation was effectively dead, restoring “American economic competitiveness” and allowing American companies to once more engage in “routine business practices in other nations”—a handy euphemism for bribery. Foreign corruption, in other words, was once more back on the table. Kleptocratic regimes and crooked American businessmen around the world rejoiced, knowing they wouldn’t have to worry about pesky prosecutions anymore. One of the greatest post-Watergate reforms was now dead, for all to see.
But Trump also had something more recent in his sights. In 2021, the US passed the country’s first shell company registry. It was the single most important tool in ending the US’s role as a global leader in creating anonymous shell companies. Without anonymous shell companies in the US, oligarchs and dictators would have far more difficult times building out their own kleptocratic networks, hiding their ill-gotten gains in American real estate, American private equity, American investments, and more.
In 2024, the registry—a private database, accessible only to American officials—finally came online. It was a remarkable moment. For the first time in decades, America’s best days as a titan of the offshore world were behind it.
And then, in early March 2025, Trump destroyed all that progress. Describing the shell company legislation as a “Biden rule”—and ignoring the fact that it was a bipartisan bill, passed over Trump’s veto—Trump claimed the new regulations had “been an absolute disaster” for small businesses. “The economic menace of [shell company] reporting will soon be no more,” he wrote.
Trump himself was, of course, no stranger to anonymous shell companies. His own real estate portfolio was drenched in them, hiding all manner of international financing networks long before he ever ascended to the presidency. Given that Trump, with his background as a luxury real estate magnate, was the first American leader to emerge from an industry reliant on anonymous shell company financing, it was perhaps unsurprising that he raced to the rescue of shell corporations. Still, the announcement was a shock; not only did fentanyl dealers, cartel heads, Chinese laundering networks, Iranian arms exporters, and more—the kinds of groups Trump was nominally opposed to—rely on these kinds of shells, but law enforcement bodies around the country were broadly supportive of shell company transparency.
Trump, though, couldn’t have cared less. As his Treasury Department said, it would no longer “enforce any penalties or fines” for American shell companies who didn’t comply with the regulations. The legislation would still remain, at least on paper. But in the real world, it would be like America’s greatest counter-kleptocracy tool had never existed. Even worse: Trump’s White House announced it would torch all the shell company data the federal government had already gathered—a collective bonfire, destroying all the corporate records shining light on American shell companies. (For good measure, the Trump White House shortly afterward announced it would also gut proposed anti–money laundering rules for things like private equity and hedge funds, meaning they, too, could continue accepting as much dirty money from around the world as they wanted.)
Trump’s actions were, in a certain sense, breathtaking. Rather than trying to repeal all these pieces of legislation outright, Trump had discovered a workaround—a legislative loophole that allowed him to decide which laws his administration would enforce, and which ones they could effectively demolish. Rather than uphold his constitutional duty to make sure that all laws passed by Congress were “faithfully executed,” Trump simply announced that there was a whole suite of legislation that folks no longer needed to worry about. He had created a new legal architecture by fiat, providing a public road map for as much white-collar crime as crooked regimes and corrupt oligarchs could want.
And still, he wasn’t done. While he was busy dismantling legislation, he was also busy creating new ways to attract illicit wealth into the US. One of his new tools was the creation of a so-called “gold card” visa scheme. Sitting in the Oval Office, Trump hawked a “path to citizenship” for anyone who could pay $5 million. Anyone—any drug lord, any human rights abuser, any oligarch around the world—who could meet that fee could visit the US, setting them on a path to American citizenship. “They’ll be wealthy and they’ll be successful, and they’ll be spending a lot of money and paying a lot of taxes and employing a lot of people, and we think it’s going to be extremely successful,” Trump said. For good measure, he held up a physical gold card for reporters to see—complete with his face, his scrawl, and the trump card emblazoned on its front.
These kinds of “golden visa” schemes aren’t novel. They’ve been a favorite tool of kleptocrats around the world, looking to purchase citizenship in offshore havens like Dominica, Malta, or Cyprus for years. They’re the perfect tools for figures looking for an escape hatch, dodging investigations or arrest alike. The US had its own related version of this years ago, but in 2022 legislators passed much-needed reforms to patch up those money-laundering loopholes. Trump, though, simply ignored those regulations. He wasn’t even coy about who he was trying to entice back into the US; when asked specifically about whether Russian oligarchs could obtain this “gold card” visa, Trump responded, “Yeah, possible. Hey, I know some Russian oligarchs that are very nice people.”
A few months later, this new Trump gold card scheme launched. The price had dropped: now, for only $1 million, anyone could “[u]nlock life in America.” American residency—and eventual citizenship—was now for sale, to anyone who could scrounge up the cash. Kleptocrats couldn’t have asked for more.
This essay is adapted from United States of Oligarchy: How America’s Wealthiest Ally With Dictators, Weaken the U.S., and Destroy Democracy by Casey Michel (Macmillan Publishers).
