During his first term in office, U.S. President Donald J. Trump drew criticism for profiting from events held at Trump-branded golf courses and housing foreign delegations at his pricey Washington hotel.
But upon his return, he has blown past all precedents on personal enrichment while also overseeing the systematic unravelling of American anti-corruption laws, institutions, and norms.
While many of these moves have been enforced by the U.S. government’s executive branch, the Republican-led Congress has done little to stop the slide — and, in some cases, has even encouraged it.
So when U.S. voters head to the polls on November 3 for midterm elections, it is not just control of the House of Representatives and the Senate that is at stake, but the future of efforts to contain corruption at home and abroad.
On the eve of the election, OCCRP spoke to experts to take stock of the state of U.S. corruption — and the fight against it — today, whether Democrats have a plan to reverse course, and what the repercussions of Trump’s actions have been at home and abroad.
The White House did not respond to requests to comment in time for publication.
How has the U.S. approach to fighting corruption at home changed under Trump?
Since returning to the White House in January 2025, Trump has taken a wrecking ball to anti-corruption programs and policies that have long been a source of bipartisan consensus.
One of the president’s first moves involved the mass firing of 17 inspectors general — non-partisan officials whose job it is to investigate misconduct, waste, fraud, and abuse across different government agencies and report back to Congress.
At least 22 inspectors general were removed during Trump’s first 18 months, and as of a week before the midterm elections, 27 posts remained vacant.
The administration didn’t provide a reason for their firing or notify Congress at the time, which a federal judge later ruled was unlawful.
The administration has also paused and weakened several key pieces of anti-corruption legislation, including a landmark 2021 law that sought to combat the flow of illicit finance through the U.S. by requiring companies to report their ultimate beneficial owners, known as UBOs.
Known as the Corporate Transparency Act, the law was meant to prevent criminals and kleptocrats from secretly stashing their wealth behind anonymous shell companies.
But this past August, the Treasury Department issued a new rule that dropped the disclosure requirement for U.S. companies and individuals, calling it a “burdensome reporting requirement.”
(This week, more than 20 U.S. states sued the administration over the rollback, arguing that laws passed by Congress can’t be undone by rulemaking.)
Erica Hanichak, co-director of the FACT Coalition, which advocates for rules to combat financial crime, describes the curtailing of the law as one of the ways the U.S. has “undeniably stepped back its fight against dirty money” over the past two years.
The consequences are far-reaching — and run contrary to the goals of law enforcement and other national security officials, she said.
When UBO information is kept secret, it makes it “harder for law enforcement and intelligence officials to follow the proceeds of financial crime, thereby handing a major win to cartels, U.S. adversaries, corrupt politicians, and fraudsters.”
In one recent example, the U.S. watchdog on federal spending noted that the lack of such data is hampering the ability to detect fraud in government contracting, leaving “hundreds of billions of federal dollars” vulnerable to “beneficial ownership-related fraud risks.”
Last year, the Justice Department prosecuted 11 people tied to a Russian transnational criminal organization that exploited the weak ownership reporting requirements to fraudulently bill the Medicare system, stealing almost $1 billion.
The Trump administration has also watered down the Foreign Corrupt Practices Act (FCPA), a 1977 law that makes it illegal for American businesses to bribe foreign officials, and which has also allowed the U.S. government to prosecute and fine foreign companies engaging in bribery if they list their stocks or debt instruments in U.S. financial markets.
Arguing that the restriction put U.S. companies at a competitive disadvantage, the administration initially paused enforcement of the law and then later published new guidelines that called for focusing on cases that undermine U.S. interests.
According to Richard Nephew, a scholar at Columbia University’s School of International and Public Affairs, the real danger goes beyond what he notes has been a significant decrease in fines and convictions.
More worrying, he has written, is what “the overall picture signals about whether the United States takes bribery seriously, and how that signal changes the risk calculus for companies deciding whether to comply.”
He pointed to Trump’s own embrace of controversial gifts while in office — the most notable of which has been a $400 million jet from Qatar set to serve as Air Force One.
The new U.S. presidential aircraft, donated by Qatar, is seen at the venue where President Donald Trump held a rally ahead of the U.S. midterm elections in Arizona on October 14, 2026.
“When the President of the United States is accepting a gold bar as a gift, it is reasonable to ask whether similar gifts given to other foreign heads of state will be seen as grounds for investigations, much less prosecutions,” Nephew wrote in the law and policy journal Just Security.
What about U.S. anti-corruption efforts abroad?
Dating back to the 1960s, successive U.S. administrations have pioneered transparency, good governance, and programs to combat corruption around the world, even if their implementation was uneven and imperfect. But the Trump administration has actively retreated from efforts to curb graft abroad in ways both big and small.
For instance, it quickly dismantled the U.S. Agency for International Development (USAID), one of the main instruments for funding anti-corruption efforts overseas, and froze the disbursement of foreign funding.
(OCCRP formerly received grants from USAID, and became a plaintiff in a lawsuit against the Trump administration for illegally terminating funding that had been allocated by Congress.)
The State Department’s Office of the Coordinator on Global Anti-Corruption — a post created in 2021 to integrate anti-corruption efforts with Washington’s foreign policy goals — was also eliminated soon after Trump took office, as was the Task Force KleptoCapture, a unit created by the Justice Department in 2022 to go after sanctions evaders, especially Russian oligarchs. The Justice Department said the latter was part of a policy realignment to focus on fighting cartels.
The administration has also stepped away from smaller but symbolic efforts to stamp out corruption overseas, such as no longer including information about corruption in the State Department’s annual country reports on human rights. (The State Department did not respond to requests to comment).
And then there’s the controversial use of the Magnitsky Act, which was passed in 2012 to allow the U.S. government to sanction foreigners who engage in corruption or human rights abuses.
The president shocked anti-corruption crusaders last year when he used the Magnitsky Act to sanction a Brazilian Supreme Court justice who oversaw the trial of Brazil’s former president Jair Bolsonaro, a Trump ally later convicted of plotting a coup after losing the 2022 election.
(The conviction prevented Bolsonaro from running for office, leading his son Flavio to take up the family mantle and narrowly lose a presidential runoff election this past Sunday. Facing a money laundering investigation in Brazil, Flavio fled the country for the U.S.)
“Global Magnitsky was a huge win when it passed … and the human rights community and the anti-corruption community celebrated,” said Gary Kalman, director of Transparency International U.S.
“Never in our wildest imagination would we have dreamed that a president of the United States would use the Global Magnitsky Act to go after a judge in another country for enforcing anti-corruption laws.”
What about Trump and his family? Have they engaged in corrupt behaviour?
U.S. presidents have historically stepped away from their personal business interests to avoid conflicts of interest, or even the perception of a conflict.
Yet Trump’s latest annual financial disclosure — which runs 927 pages long and covers his first year back in office — shows a significant increase in his income while president. Last month, Forbes estimated he was $2.7 billion richer than when he won the 2024 election.
The source of this wealth comes from cryptocurrency enterprises, Trump-owned resorts and real estate, his social media platform Truth Social, and a range of other business ventures, many of which are rife with potential conflicts of interest.
“I don’t think that there’s any president who has so brazenly used their office to create a web of foreign entanglements that enriches himself, his family, and some of his closest advisors and their families,” said Matthew Dallek, a historian specializing on presidential politics at George Washington University.
The examples to choose from are numerous. For instance, the collective Trump fortunes soared earlier this year when an investment firm reportedly connected to the United Arab Emirates’ ruling family bought nearly half of a Trump family-connected cryptocurrency company.
A company backed by Trump’s sons has also sought to sell drone interceptors to Gulf countries while they were under attack by Iran following a war started by their father.
Trump and other officials’ frequent visits to the president’s properties, meanwhile, generate advertising and revenue for those businesses — and open up avenues through which others can use their wallets to try to curry favor with the president.
Taken together, experts have described it as an unprecedented level of political profiteering that raises the risk of the president putting his business interests ahead of those of the country.
It’s also a problem that won’t be easy to fix.
Trump’s second term has exposed just how much the U.S. presidential system depends on “an adherence to norms and a set of expectations and values…rather than strict rules and laws preventing a president from corrupt actions,” Dallek said.
In previous comments to the press, a White House spokesperson has stated that “neither the president nor his family has ever engaged — or will ever engage — in conflicts of interest.” When asked about his lucrative year following the release of his financial disclosures this June, Trump attributed the profits to the stock market “going up” and said he never spoke to the people who manage his money.
“We are experiencing what happens when you have an individual who dismisses ethical norms,” said Kalman of Transparency International. “People are now trying to figure out how you close these kinds of gaps in our ethics rules at the highest levels of our government.”
One avenue, he said, is to secure the roles of state actors that could provide a counterweight to the Justice Department, whose independence has been called into question as it has pursued investigations against the president’s opponents and dropped cases involving allies.
“I think there’s a lot of district attorneys and law enforcement officials that are concerned about what they’re seeing as the weaponisation of the Justice Department,” said Kalman. “If the U.S. Justice Department gets taken over by the executive, you have what we have now, which is a lack of accountability or unwillingness to enforce any of the violations that we’ve seen happen.”
The Justice Department did not respond to requests to comment.
Democrats are trying to take back Congress. What is their plan if they succeed?
Polls show voters cite corruption as a major concern, and Democrats have pledged to investigate corruption if they regain control of one or both chambers of Congress.
Should they win back at least the House of Representatives, they would be in a position to legislate and hold oversight hearings. They’ve already signalled plans to spotlight the business entanglements of the Trump family and friends, and say they won’t be shy about using their power to subpoena witnesses.
“We can bring in members of the Cabinet and ask them questions and perhaps see if there’s any way we can get rid of some of them,” Rep. Dina Titus, a Nevada Democrat on the House Foreign Affairs Committee, told OCCRP. Her panel will “look at some of this corruption that’s going on around the rest of the world involving the administration and some of their buddies and relatives,” she added.
Much of what Democrats will be able to do hinges on the size of their victory, and some of their plans have yet to be spelled out in detail.
“Democrats are running on corruption, but they’re not running on a specific platform of how they’re going to reform or fix the system or address many of Trump’s egregious acts,” said Dallek, the historian.
In a recent interview with the TV outlet MS Now, New York Democrat Hakeem Jeffries, the current House minority leader, outlined plans for the first 100 days of the next Congress that included empowering two committees to look into corruption.
He has said the Judiciary Committee and the House Oversight Committee would be tasked with accountability and looking into the Trump family business entanglements.
“We’re going to follow the facts, apply the law, be guided by the Constitution and then let the chips fall where they may,” he said.
Congressional Republicans, for their part, have prominently used their oversight powers to investigate people named in or associated with the Epstein files, including Commerce Secretary Howard Lutnick. The committee has also investigated tax breaks given to politically opposed non-profit organisations, while their anti-corruption agenda has largely been focused on reversing the “Censorship Industrial Complex,” a term used to describe those they say are suppressing right-wing viewpoints online under the pretence of limiting disinformation.
Hanichak, from the FACT Coalition, called on the next Congress — regardless of who holds the reins after Tuesday — to “strengthen guardrails to prevent public officials from profiting from power.”
“We are what we tolerate: in most cases, the recent reticence of both Republicans and Democrats to denounce corruption by colleagues in their own parties has bred public distrust about the sincerity of reform,” she said.
“We need more transparency and accountability — in elections, in our financial system, in government contracts and services — to restore faith that democracy can deliver for ordinary people.”
