70 Am. U. L. Rev. 2043 (2021).

*  Senior Note & Comment Editor, American University Law Review, Volume 71; J.D. Candidate, May 2022, American University Washington College of Law; M.A. Candidate, May 2023, American University School of International Service; B.A. International Affairs and Business Administration, 2014, Northeastern University; A.A.S., Advertising, Marketing Communications, 2011, Fashion Institute of Technology. Thank you to the entire Law Review staff, especially to my editor, Ari Bental. I would also like to thank Professor David Hunter for the inspiration and support. Finally, I am forever grateful for the constant support and encouragement of my family and friends throughout my law school career.


The world is facing increasingly global challenges like climate change, growing income inequality, financial crises, and the COVID-19 pandemic. These challenges disproportionately impact economically developing countries. Development Finance Institutions (DFIs) and International Finance Institutions (IFIs) are tools that the international community deploys to mobilize private capital to support development projects around the world. The International Development Finance Corporation is a newly formed U.S. DFI that consolidated the United States’ development finance initiatives into one government entity.

The U.S. International Development Finance Corporation (DFC) is a bilateral entity that receives funding from the U.S. government to further economic advancement in developing countries, but it is unclear which aspects of domestic law apply to the DFC and its accountability mechanism. This Comment argues that the DFC is an “agency” under the Government in the Sunshine Act (“Sunshine Act”), the Freedom of Information Act (FOIA), and the Administrative Procedure Act (APA), as supported by the transparency mandates in the Better Utilization of Investments Leading to Development (BUILD) Act of 2018 and international standards.

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