TRANSPARENCY 

POLICY

Responsible Office: Office of the Chief Development Officer Effective Date: 12/18/2023 
 

Version Description Date Updated or 

Reviewed

Reviewer

Version 1.0 Initial publication of 

Transparency Policy 

12/4/2023 Lawrence Sacks, Chief 

Development Officer
 

TABLE OF CONTENTS

1. INTRODUCTION............................................................................................................................. 1 

2. LEGAL DISCLOSURE REQUIREMENTS ............................................................................................ 2 

3. TRANSACTION-LEVEL DATA .......................................................................................................... 3 

4. APPROACHES................................................................................................................................. 4 

5. INSTITUTIONAL/CORPORATE INFORMATION ................................................................................. 4 

6. FEEDBACK........................................................................................................................................ 5 
 

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1. INTRODUCTION 

DFC Introduction 

1.0 The U.S. International Development Finance Corporation (DFC) is the United States of America’s 

development finance institution. DFC invests with the private sector to finance solutions to address 

many of the most critical challenges facing the developing world. We invest across sectors 

including energy security, healthcare, food security and agriculture, critical infrastructure, and 

technology projects. DFC also provides financing for small businesses, including women 

entrepreneurs, that are the engines of economies and create jobs in emerging markets. DFC 

investments adhere to high standards and respect the environment, human rights, and worker rights.

Statement of Purpose and Scope 

1.1 DFC strongly affirms the importance of transparency and strives for increasingly proactive, 

accessible, open, and machine-readable disclosures. This policy sets out the principles that guide 

DFC’s proactive public disclosure of programmatic and project-related information, as well as the 

scope and type of information and data that it routinely discloses. Information and data disclosure 

related to interagency cooperation, congressional oversight, DFC’s Office of Accountability, and 

the Freedom of Information Act (FOIA) 22 C.F.R. Part 706 are not subject to this policy. 

1.2 It is essential that the benefits of transparency are balanced against the benefits of safeguarding, 

promoting, and preserving internal deliberative processes that can lead to more informed and 

collaborative decision-making, as well as more thoughtful DFC policies. Further, DFC will not 

disclose information that would violate its mission-critical commitment to the protection of 

business confidential information. To do so would be contrary to the legitimate expectations of 

clients, who need to be able to disclose to DFC detailed and/or sensitive information without fear 

of compromising the confidentiality of their projects or other proprietary information that would 

limit market competition. DFC will also not disclose information that is protected under the law, 

or that would be infeasible for DFC to collect systematically and reliably.

Implementation and Oversight 

1.3 This policy is implemented and overseen by the Chief Development Officer (CDO) in coordination 

with the Chief Information Officer (CIO), supported by an internal Transparency Committee, 

consisting of representatives from different areas of the institution. The composition and 

membership of the Transparency Committee will be publicly available on DFC’s website, and the 

Transparency Committee may be reached at transparency@dfc.gov.

1.4 The Policy will be reviewed in full every two years, or as otherwise necessary, to incorporate any 

changes to disclosure requirements, including those of the United States Government (USG), 

particularly where new requirements exceed the transparency provisions herein.
 

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2. LEGAL DISCLOSURE REQUIREMENTS

2.0 The Better Utilization of Investments Leading to Development Act of 2018 (BUILD Act) mandates 

that DFC “shall make available to the public on a regular basis information about support provided 

by the corporation under title II and performance metrics on a country-by-country basis.” 

Section 1443 of the BUILD Act requires that at the end of each fiscal year DFC submit a complete 

and detailed report of its operations during that fiscal year to the appropriate congressional 

committees, including an assessment of:

1. Economic and social development impact

2. Extent that Corporation operations are compatible with the development assistance 

programs of the United States 

3. Institutional linkages with other relevant USG department and agencies 

4. Compliance of Corporation projects with human rights, environmental, labor, and social 

policies

DFC's Congressional Reporting Requirements under the BUILD Act are contained in DFC's 

Annual Report (see section 5). 

Section 1444 of the BUILD Act requires that DFC (1) maintain a user-friendly, publicly available, 

machine- readable database with detailed project-level information, as appropriate and to the extent 

practicable, including a description of the support provided by DFC including project-level 

performance metrics where feasible; and (2) include a clear link to information about each project 

supported by DFC online. DFC currently provides project data on DFC's website, at 

www.dfc.gov/data. 

The BUILD Act also requires that projects likely to have significant adverse environmental or 

social impacts that are sensitive, diverse, or unprecedented are assessed for their environmental and 

social impact, and the assessments are made public prior to a DFC Board vote1

 (See section 3.4). 

2.1 In accordance with the U.S. Office of Management and Budget’s (OMB) guidance on the collection 

of U.S. foreign assistance data (Directive 12-01), DFC is committed to transparency and 

accountability to promote responsible stewardship of federal resources, operational efficiencies, 

engagement with stakeholders, development effectiveness, and public trust.2

2.2 The Foreign Aid Transparency and Accountability Act of 2016 (FATAA) establishes a range of 

objectives related to monitoring and evaluation of DFC’s portfolio.3 OMB’s implementing 

guidance (OMB M-18-04) requires agencies to publicly report evaluations. It requires DFC to 

1 22 USC 9671(e), See also Section 4.2. 2 DFC discloses information regarding its investment activities and internal operations to contribute to the 

transparency of foreign assistance flows that will enable the USG to pursue the following objectives of Directive 

12-01: make foreign assistance more useful for development; increase the efficacy of USG foreign assistance; and 

increase international accountability.

3 Section 3(b) and 3(c)(2)(A-M). 
 

3 

report on the implementation of monitoring and evaluation policies and practices outlined in the 

Memorandum through the agency’s annual budget submission process. 

2.3 The Federal Funding Accountability and Transparency Act of 2006 (FFATA) mandates U.S. 

government agencies to monitor, evaluate, and report on U.S. covered foreign assistance programs 

and share these data with the public. The Digital Accountability and Transparency Act of 2014 

(DATA Act) established standards for financial data and a new reporting process for agencies to 

improve data quality, transparency, and accountability. DFC provides information about its 

investments on multiple U.S. Government websites including ForeignAssistance.gov and 

USASpending.gov. 

2.4 DFC adheres to the Information Quality Act Guidelines on data shared with the public in 

accordance with Section 515, Treasury and General Government Appropriations Act (Pub.L. 106-

554), ensuring that useful corporate data shared publicly will have relevance, reliability, 

comparability and understandability, and any public financial statements will strive to achieve 

transparency through fair presentation of useful, trustworthy information. In adherence to OMB 

Memorandum M-19-15, Improving Implementation of the Information Quality Act, the public may

request changes to incorrect published data following the processes described on DFC’s website. 

2.5 DFC contributes data to the Treasury Department’s Foreign Credit Reporting System (FCRS), 

which consolidates and publishes foreign credit data.

4 This and other data is factored and published 

to the Organization for Economic Co-operation and Development (OECD) Creditor Reporting 

System (CRS). 

3. TRANSACTION-LEVEL DATA

Disclosure of Investments Post-Approval

3.0 DFC provides information on business activities with active clients after legal agreements have 

been signed. DFC maintains a database on DFC.gov, providing information on every active 

transaction in its portfolio, including a summary of their expected environmental, social, and 

developmental impacts. Transactions are searchable by country and region, year, project name, and 

type of investment. These resources are updated approximately 45 days after the end of each 

quarter. 

3.1 Data on individual investments are also reported in DFC's Annual Report, including Investment 

Funds’ investments (see Section 5). 

3.2 DFC provides additional information on investments made through DFC-supported Financial 

Intermediaries, Credit Facilities, and Investment Funds, when such investments are $10 million or 

more. DFC also provides additional information on all investments that are high-risk from an

4 2 TFM 4500.
 

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environmental and social perspectives, regardless of the investment amount, made through 

Financial Intermediaries, Credit Facilities, and Investment Funds. 

Disclosure of Investments Pre-Approval

3.3 It is the policy of the Board of Directors (Board) for transactions that require Board approval, DFC 

publicly discloses the project information summaries at least seven (7) days in advance of the Board 

meeting or action (see Section 5 for more details). 

3.4 DFC provides advance notice of potential projects considered to have significant adverse 

environmental and/or social impacts that are irreversible, sensitive, diverse, or unprecedented

(Category A). Under Section 1451(e)(1) of the BUILD Act, the environmental and social impact 

assessments for Category A projects are disclosed on DFC's public website for a designated 

comment period of not less than 60 days prior to DFC support. For more specific information on 

DFC’s approach to environmental and social impacts and disclosures please see DFC’s 

Environmental and Social Policy and Procedures (ESPP). 

4. APPROACHES 

Development Impact

4.0 DFC discloses an overview of its impact management tools on its website. 

Environmental and Social Impact

4.1 DFC’s Environmental and Social Policy and Procedures address DFC’s commitments for 

environmental and social screening, review, risk mitigation, and monitoring that are designed to 

help ensure the environmental and social sustainability of DFC-financed projects. The ESPP also 

includes guidance for what DFC Clients need to prepare, submit, and implement. These 

environmental and social requirements described in the ESPP apply to all DFC projects and clients 

supported through insurance, reinsurance, direct loans, investment guaranties and equity, including 

support through financial intermediaries. The ESPP is published on DFC’s website.

5. INSTITUTIONAL/CORPORATE INFORMATION 

5.0 It is the policy of the Board of Directors (Board) to provide as much public visibility into its 

practices and decisions as possible while honoring sensitive and business confidential information. 

DFC’s Board hosts semiannual public hearings. DFC posts notices and agendas of upcoming Board 

meetings seven (7) days in advance, summaries of all projects approved by the Board, and approved 

Board Resolutions. Non-business confidential summaries of transactions put forth for approval by 

DFC’s Board are posted to DFC’s public website seven (7) days prior to the Board’s final 

consideration. Directly following each Board meeting, a summary of the Board’s actions is posted 

on DFC’s website and released to the press and public. DFC’s Corporate Bylaws and Public 

Engagement Policy are available on our website. 
 

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5.1 DFC's Annual Report includes the Agency’s financial statements, a complete list of commitments 

made during the fiscal year, and development impact projections and results that outline DFC’s 

progress in achieving Agency priorities. Development impact data are aggregated on a regional 

(and country specific basis, where possible) and sector basis. 

6. FEEDBACK 

6.0 DFC recognizes that meeting the reasonable information needs of the public is critical to its 

effectiveness and public trust. To that end, DFC strives to be as transparent as possible while 

balancing all stakeholders’ interests. 

6.1 Additional feedback on ways DFC can improve transparency can be directed to 

transparency@dfc.gov.