A Classic Kleptocracy Case Continues

One of former Attorney General Pam Bondi's early actions was to disband the Department of Justice's Kleptocracy Team (housed within the Criminal Division's Money Laundering, Narcotics, and Forfeiture section) and direct the prosecutors on that team, who had investigated foreign officials suspected of laundering the proceeds of corruption through the U.S. financial system, to instead focus on “the total elimination of Cartels and TCOs [transnational criminal organizations]." Coupled with the freeze on FCPA enforcement, this dismantling raised major questions about how much this Administration was planning to roll back enforcement of laws targeting corruption abroad.  

With this background in mind, I was interested to read the Department of Justice's press release announcing that it was returning $2.5 million in seized corruption proceeds to the Republic of The Gambia. Quotes from Criminal Division AAG Tysen Duva and Homeland Security Investigations trumpet DOJ's and HSI's commitment to preventing the illicit use of the U.S. financial system by corrupt foreign officials and returning funds to victims abroad harmed by corruption.  

This appears to be the result of a classic kleptocracy case: the DOJ's Money Laundering, Narcotics, and Forfeiture section filed a complaint in Maryland to forfeit a mansion in Potomac, Maryland, alleging that the former president of The Gambia and his wife had bought the property with embezzled public funds and bribes and that the property was forfeitable because it was involved in or was the proceeds of money laundering.  The complaint outlines how the former president stole or diverted public funds and received bribes in exchange for granting exclusive contracts and monopoly rights, in violation of the laws of The Gambia, and traced the purchase of the property to a $1 million payment from a petroleum company.  

This case is not new: DOJ's complaint was filed in 2020 (during the first Trump Administration), and an investigation preceded that. DOJ obtained a default judgment and final order of forfeiture against the house back in 2022.  Last week's press release simply notes the return of funds to The Gambia.  So it would be an overreach to read this development and conclude that the DOJ's anti-kleptocracy money laundering enforcement was back to its pre-2025 state. But it is a signal that this work continues.   

Press Release: Department of Justice Returns Approximately $2.5 Million in Corruption Proceeds for Victims of the Ex-President of The Gambia

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