USA – Non-financial reporting

Section III: Additional National Action Plan Commitments
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Table 1: Expanding Engagement and Coordination on Responsible Business Conduct Commitments

The Department of State will “evaluate and assess the impact of potential approaches to implementing RBC Reporting Requirements, which would build on previous models of public reporting related to HRDD and RBCrelated issues. The United States and other governments have employed a range of models for public reporting on RBC, noting both challenges companies face in providing information that may be sensitive, confidential, or involve security or other such risks. Public reporting is an integral part of robust HRDD, and State will work with other agencies to identify approaches that can build on lessons learned to assess potential model(s).” (p.15)

Table 7: Anti-Corruption Commitments

The Department of the Treasury will “continue to implement the Corporate Transparency Act (CTA) to enhance beneficial ownership transparency for legal persons in the United States. The continued implementation of the FinCEN rule on beneficial ownership information reporting provisions and the revision of FinCEN’s 2016 Customer Due Diligence Rule will aid in the implementation of the CTA and strengthen beneficial ownership transparency for legal persons, such as shell and front companies, in the United States to prevent their misuse by illicit actors. On January 1, 2024, FinCEN launched a beneficial ownership filing system pursuant to the CTA. Under this new framework, many companies operating in the United States are now required to report information to FinCEN about their beneficial owners – in other words, the real people who own or control them. This effort will make it more difficult for illicit actors – including corrupt officials, terrorist financiers, criminal organizations, and drug and human traffickers – to misuse opaque corporate structures like shell companies to launder the proceeds of crime.” (p.38)