USA – Finance & banking sector

Section II: Priority Areas of the National Action Plan on Responsible Business Conduct

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3. Priority Area (3) Strengthening Access to Remedy: “[…] agencies and offices will strengthen USG-based due diligence processes and grievance mechanisms in consultation with external stakeholders through the following measures, all of which are further elaborated upon in Section III:

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• U.S. Department of the Treasury (“Treasury”): Treasury will advocate for effective remedy systems at multilateral development banks, including the International Finance Corporation (IFC) and Multilateral Investment Guarantee Agency (MIGA), for project-affected communities, which includes robust responsible exit principles.
• Export-Import Bank of the United States (EXIM): EXIM will engage with Export Credit Agency (ECA) counterparts on strengthening remedy procedures and will engage in public outreach to solicit input on how to improve access to remedy and the efficacy of project-based grievance mechanisms. (p.12-13)

Section III: Additional National Action Plan Commitments

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Table 3: Access to Remedy Commitments

The Department of the Treasury will “advocate for an effective remedy system at multilateral banks, including IFC and MIGA, which includes robust principles on “responsible exit.” This advocacy will inform IFC and MIGA’s development of the “IFC/MIGA Approach to Remedial Action.” This approach seeks to minimize the occurrence of environmental and social harm in IFC and MIGA projects through improving the implementation of environmental and social safeguards, while also supporting remedial action to communities to address harm when needed.” (p.23)

Table 4: Technology Commitments

The Department of State will “work with Treasury to convene an interagency working group to strengthen human rights safeguards that apply to multilateral development bank funded telecommunications infrastructure projects.” (p.28)

Table 7: Anti-Corruption

The Department of the Treasury will “assess and address the illicit finance risks associated with key financial gatekeepers – such as accountants, lawyers, real estate professionals, investment advisers, and trust and company service providers – and consider potential steps to address these risks. Certain types of financial intermediaries, gatekeepers, and other professions or sectors are not covered by comprehensive and uniform Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT) obligations and face varying levels of illicit finance risk exposure. This assessment and subsequent action are meant to address the uneven application of AML/CFT measures to key gatekeeper professions and sectors and work to address those risks. On February 7, 2024, Treasury released its 2024 Money Laundering, Terrorist Financing, and Proliferation Financing Risk Assessments, which discuss these issues. In addition, on February 13, 2024, Treasury issued a sectoral risk assessment of the investment adviser sector.” (p.38-39)