Less Oversight, Less Funding: Why International Organizations Face a Growing Corruption Risk

For decades, international organizations (IOs) have relied on two critical safeguards to protect development and humanitarian operations from corruption:

  • Strong enforcement of the Foreign Corrupt Practices Act (FCPA), which has deterred corporate bribery in international contracts.

  • Robust development funding from key donors like USAID and the UK’s Foreign, Commonwealth & Development Office (FCDO), enabling projects to operate transparently and with proper oversight.

But in 2025, both of these foundations have come under threat.

Earlier this year, U.S. President Donald Trump signed an executive order instructing the Department of Justice to halt FCPA prosecutions, claiming the law placed American companies at a competitive disadvantage. This weakens one of the most powerful tools in global corporate anti-corruption enforcement—at the same time that foreign aid budgets are being slashed.

The result? A perfect storm: fewer legal consequences for corporate misconduct and fewer resources for oversight in aid-funded projects. For international organizations that rely heavily on private-sector suppliers and implementers, this new environment presents serious risks to procurement integrity, financial accountability, and program delivery.

Weaker Corporate Compliance Means Higher Corruption Risks

International organizations frequently contract private firms for logistics, infrastructure, healthcare supply chains, security, and more. Historically, the FCPA’s global reach required these companies to maintain strict anti-bribery programs to remain eligible for donor-funded contracts.

But with FCPA enforcement paused, corporate incentives for compliance are already weakening. This shift poses multiple risks for IOs:

  • Bribery and bid-rigging may rise in procurement processes.
  • Companies may cut compliance corners, reducing contract integrity.
  • Fewer checks and balances make it harder to ensure ethical partnerships.


Many UN agencies and INGOs work with multinational logistics providers to transport aid into conflict zones. If a supplier, no longer fearing FCPA prosecution, offers bribes to secure contracts, the result could be inflated costs, favoritism, and unethical business practices—compromising the integrity of humanitarian operations.


Less Enforcement Could Make it Harder to Hold Private-Sector Partners Accountable


International organizations have long relied on FCPA enforcement as a tool to assess risk, vet suppliers, and prevent fraud in aid and development projects. When companies are prosecuted under the FCPA, it provides clear evidence of misconduct, helping IOs identify high-risk partners and enforce procurement integrity measures.

With U.S. authorities scaling back FCPA enforcement while also reducing aid budgets, IOs now face heightened challenges in upholding integrity:


  • Fewer corporate bribery cases surfacing. A decline in FCPA prosecutions means fewer corporate bribery cases will come to light—not only in the U.S. but also globally, as multi-jurisdictional cooperation may weaken. This reduces IOs’ ability to identify and mitigate corruption risks before awarding contracts.
  • Weakened debarment and compliance monitoring mechanisms. Many IOs rely on FCPA cases not only to blacklist unethical firms but also to promote improvements to compliance programs. If fewer prosecutions and settlements take place, corrupt actors may continue securing donor-funded contracts, while compliance standards stagnate—even as corruption risks continue to evolve.
  • Greater incentives for corruption. As U.S. aid budgets and contributions shrink, the number of IO-funded contracts awarded to private sector entities will likely decrease. With fewer contracts available, competition will intensify. In an environment where FCPA enforcement is weaker, some companies that depend on donor-funded contracts may resort to bribery or other unethical practices to remain competitive—especially in high-risk markets with weak oversight. This increases the likelihood of fraud, reputational damage, and compromised project outcomes for IOs.


This evolving reality means international organizations must take a more proactive approach to supplier due diligence and contract oversight. Without strong external enforcement, IOs will need to strengthen internal safeguards to prevent corruption in a rapidly shifting landscape.


Undermining Global Anti-Bribery Norms


The U.S. has long been a global leader in corporate anti-corruption enforcement, shaping international frameworks like the United Nations Convention Against Corruption, the UN Global Compact, and the OECD Anti-Bribery Convention.


The UN Global Compact, as an example, encourages businesses to uphold FCPA-style anti-bribery commitments. However, if companies perceive that the U.S. is no longer prioritizing enforcement, they may deprioritize voluntary compliance—weakening corporate integrity in international development projects. Voluntary frameworks like the UN Global Compact rely on a climate of active enforcement to maintain influence.


FCPA settlements have also been a way to push for the improvement of compliance programs in the private sector, as companies settling typically commit to extensive changes to their compliance programs and independent expert monitoring of their implementation. FCPA compliance guidelines have inspired most of the MDBs’ approach to post-integrity sanction compliance guidelines and programs. Reduced FCPA enforcement means a lesser push on the private sector to update and innovate in compliance to stay on top of emerging corruption risks.


What Comes Next? Navigating an Era of Uncertainty


The global anti-corruption landscape is shifting rapidly. In a short period, we’ve seen aid budgets slashed and FCPA enforcement disappear. These recent changes may not last—but they do create new risks for international organizations, demanding a more adaptive approach to accountability and oversight.


  • Will IOs rethink integrity risk assessments?
  • Should procurement teams implement stricter oversight?
  • Can international anti-corruption initiatives and IOs take a more proactive role in closing the enforcement gap?


These changes may not be permanent, but the risks they introduce are real. In this uncertain environment, waiting is not a strategy.


International organizations must:


  • Reevaluate how they assess integrity risk in the absence of external enforcement
  • Strengthen internal oversight mechanisms, especially in procurement
  • Collaborate across the sector to fill the enforcement gap left by weakened FCPA action


Final Thoughts


The landscape has changed—and so must the response. Whether the halt in FCPA enforcement is temporary or part of a broader trend, international organizations must be ready. Stronger internal accountability, better supplier oversight, and agile risk management will be essential to uphold integrity in an era of reduced external controls.

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Hi, I'm Sârra-Tilila!

I help international organizations and NGOs strengthen their integrity frameworks through internal policy development, tailored trainings, misconduct investigations, and dispute resolution. With over a decade of legal and investigative experience, I’ve worked extensively in Africa and collaborated with global giants like the World Bank and the World Food Programme.


My work is driven by a deep passion for tackling fraud and corruption while promoting transparency and accountability in international development. If you’re looking for expert support to achieve your organization’s integrity goals, let’s connect!

© 2022 par Sârra-Tilila Bounfour