Combatting international corruption: The pro bono research behind the landmark Foreign Extortion Prevention Act

The lack of legislation in the USA that criminalised a foreign official demanding or accepting a bribe from an American or American company has long been a block on tackling the root causes of corruption around the world.

To help combat this issue, TrustLaw, the Thomson Reuters Foundation’s global pro bono service, connected the anti-corruption NGO, Transparency International, with the law firm Foley Hoag LLP, to push for new legislation.

To celebrate this project’s nomination for an Impact Award as part of the 2025 TrustLaw Awards, we caught up with Chistopher Hart, Partner at Foley Hoag LLP and Scott Greytak, Director of Advocacy at Transparency International U.S, to delve deeper into the impact and vision that drives their work forward.

What challenge were you facing?

“We needed to understand the limits of the U.S. Government’s authority to go after foreign officials who demand bribes from Americans or American companies—even when those demands take place outside the United States.”

_{– Scott Greytak}

Why were you keen to work on this project?

“Foley Hoag has worked with Transparency International in the past, and I am a firm believer in the organisation’s anti-corruption mission. This project—analyzing the potential constitutional challenges to a bill designed to reduce foreign corruptive influence in the U.S. through funding and lobbying, among other things—was an opportunity to help the organisation with a high-impact way of stemming corruption in government. ”

_{– Christopher Hart}

What did the pro bono lawyers give you to support?

“The lawyers helped explain the power, reach, and legality of the Foreign Extortion Prevention Act—then only a legislative idea—to stop foreign officials from demanding bribes. The lawyers looked at international and national laws and agreements in order to help us design the legislation.”

_{– Scott Greytak}

What has the support helped you achieve?

“Their help allowed us to design and push for a new law—the Foreign Extortion Prevention Act—that was ultimately passed by Congress and signed into law by President Biden. It is very likely the most important anti-foreign-bribery law in the world.”

_{– Scott Greytak}

How do you feel about the impact the work has had?

“Any legal analysis of proposed legislation can be extremely valuable not only for the success of a bill’s passage, but also for the success of its implementation and the reputation of the organizations lobbying for its passage. I saw our work as having a number of positive effects both in strengthening a bill to withstand constitutional challenges and in helping to maintain Transparency International’s stellar reputation.”

_{– Christopher Hart}

Was there anything that stood out for you about the way the legal assistance was delivered by the law firm that helped make the project successful?

“The lawyers were incredibly responsive, detail-oriented, and practical. They understood what Congress and other stakeholders needed to see to support the law and broke down very complex issues in a way that made the legislation easier to support. ”

_{– Scott Greytak}

Why is it important for law firms to do pro bono projects like this?

“Law firms are uniquely positioned to devote significant resources—both in time and in expertise—to help NGOs in their work. NGOs are often the only organisations willing to put resources into important efforts like advocating for anti-corruption. A law firm’s pro bono resources can be put to excellent use in helping NGOs fulfill their mission through the provision of legal expertise that NGOs might not otherwise have access to.”

_{– Christopher Hart}