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Former investment advisor Joan McCarthy facing 24 criminal charges – CBC.ca

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A former Newfoundland investment advisor is facing two dozen criminal charges, related to allegations of fraud and forgery.

Joan McCarthy, 53, is set to make a first appearance on the charges Tuesday morning at provincial court in St. John’s.

That’s just two days before McCarthy is scheduled to face separate disciplinary proceedings by the regulator that oversees all investment dealers in the country.

The Investment Industry Regulatory Organization of Canada, or IIROC, has accused McCarthy of falsifying signatures and appropriating $775,000 from the accounts of six elderly clients over a 13-year period.

The criminal charges span the same time frame, from 2006 to 2019, and the same number of alleged victims.

McCarthy is facing 24 counts in total — six each of fraud over $5,000, forgery, using a forged document, and possession of property obtained by crime.

According to IIROC, McCarthy was employed by MD Management Limited at its St. John’s branch from 2000 through March 2019, and has not worked for a regulated firm since.

On Monday afternoon, IIROC officials gave an evolving series of updates to CBC News on what is expected to happen when McCarthy appears before the regulator later this week.

There will be a brief public initial appearance, that will mainly consist of the parties and the panel deciding on dates.

After that concludes, the proceedings will move behind closed doors, for a prehearing conference.

IIROC’s allegations against McCarthy have not yet been proven.

At this point, she hasn’t had the opportunity to enter a plea to the criminal charges.

Read more from CBC Newfoundland and Labrador

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Don"t let investment goals be blinded by interest rate rise – Proactive Investors Australia

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A week ahead of the next expected interest rate rise, Wealth Management principal at Picher Partners, Andrew Wilson, discusses how the landscape will change for leveraged investors, but why this isn’t time to panic.

In this article:

More than $650 million in loans were drawn down in April alone for the purpose of personal investment and that doesn’t include financing property.

Investors have enjoyed low interest rates across the last few years but now the cost of money is turning skywards. Indications are that the Reserve Bank is not yet finished hiking interest rates, and as lenders inevitably follow suit, the landscape will change for leveraged investors.

Rates going up should not mean hitting the panic button and ripping up investment plans, but it might mean tweaking the strategy to make sure your goals stay in view.

Start your review with remembering why you borrowed in the first place – to deliver on your unique investment objectives. Whether it’s planning for retirement or funding a project, your goals give direction and purpose to the financial plan.

Readjust your stride

Hurdles are not just for track athletes. The hurdle rate is a factor taken into consideration when borrowing for investment.

Let’s assume the cost of borrowing for investment purposes is 3%. With a salary in the top marginal income tax rate, the after-tax interest cost, or hurdle rate, is approximately 1.5%.

A borrowing to invest strategy is profitable, if the investment return exceeds the hurdle rate.

Over the last two years, the hurdle rate has been exceptionally low, around 1.5% to 2%. Most asset classes have exceeded that with ease and therefore investors have generated a profit.

As interest rates rise, that hurdle rate will start to get higher and more challenging to get over.

It is still plausible to clear a hurdle rate that reaches 4% or 5% if you’re investing in growth assets but an annual return below the hurdle rate will become more frequent and the strategy can oscillate more frequently between a gain and loss position.

Investors will need to be more selective about the assets they invest in and focus more on the cash flow of the gearing strategy.

A buffer is an amount added to the hurdle rate to allow for interest rate increases and unforeseen cash flow issues. It is prudent for investors to review what their cash flow would look like if interest rates increased by 1.5-2.5%.

If this extra interest cost is not manageable, investors can get ahead of the curve by reducing their gearing level before their financial position becomes too tight. Equally, you can re-assess whether borrowing is required at all to achieve your objectives.

If you can achieve your objectives without borrowing to invest, you may be taking unnecessary risk by implementing a gearing strategy.  

Cut your interest bill down

Many investors have multiple debts – some deductible, some non-deductible. As a rule of thumb, it makes sense to repay your non-deductible debt sooner than your deductible debt, because a tax benefit can be claimed on the deductible debt.

Consolidating debt is a common strategy for investors with multiple loans. Consider refinancing higher-cost loans into your lowest-cost loan to reduce your overall interest cost. Noting that it is generally not recommended to consolidate deductible and non-deductible debt.

An offset or a redraw facility is also useful for borrowers. These allow investors to offset the interest costs incurred on the loan. For investors with a debt outstanding, it does not make sense to accrue cash in a bank account, earning a lower rate of interest, while incurring a higher rate of interest on outstanding debts.

Any income, including a salary, could be directed straight into the offset account, even if it only saves a week or two weeks of interest cost on a loan. When that’s compounded over a 10- or 20-year period, it makes an enormous difference.

Consider the exit strategy

Often people get frustrated that financial institutions won’t lend them large sums against a high-value asset. In the investor’s mind, the calculations make sense – they want to borrow $1 million and they have $2 million in assets to secure it against, so why doesn’t the bank provide the financing?

The bank needs an investor to have sufficient cash flow to repay the debt because that is the primary exit for a debt. Selling the asset to repay the loan is the backup strategy, not plan A.

Use this mindset when examining a personal gearing strategy by making sure you have enough cash flow to repay the debt, plus a margin of safety. If you’ve borrowed at 3%, borrowing costs of 5% should be factored in as a buffer against interest rate rises in the future.

If you are relying on selling assets to extinguish the debt at retirement, there is considerable timing risk in trying to sell the asset at a high point. For a portfolio of assets, consider gradually selling down over an extended period to average your exit price. Or, for single-asset strategies, such as real property, be prepared to be flexible on your sale date.

Being a forced seller when markets are down will be a painful experience.

There’s no doubt there are a few investors feeling edgy about what the future holds, with the rising cost of borrowing and concerns about growing their wealth.

As rates go up, use it as a catalyst for reviewing the investment plan, and factoring in the additional risk that comes with borrowing to invest. Take some time out to assess your position and make sensible adjustments but don’t lose sight of your goals.

About the author

After a decade working in two senior roles at Australia’s largest and longest-standing financial institutions, Andrew Wilson joined Pitcher Partners, working his way up to principal in a short time. He provides his clients counsel and guidance on all financial matters as part of an ongoing relationship, focusing on helping clients build sufficient passive investment income. Andrew’s expertise cover investment management, tax minimisation, debt management, asset protection, retirement planning and estate planning.

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Hugo Ekitike: Bayern Munich Consider $40m Investment For Future Star – Forbes

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Bayern Munich is ready to jump in the Hugo Ekitike sweepstakes should they sell Robert Lewandowski to Barcelona this summer. Internally, the decision-makers at the Rekordmeister rate the 20-year-old French striker very highly; however, there are some obstacles before a deal even be considered.

The primary question is the future of star striker Lewandowski. The Polish forward has made it quite clear that he wants to leave Bayern this summer and join Barcelona. Publicly, Bayern bosses Hasan Salihamidzic and Oliver Kahn have been very outspoken when it comes to not selling Lewandowski.

Internally, the situation is a bit different. With Lewandowski making strong comments about wanting to leave, many players in the squad have voiced their discontent and doubts about whether the 33-year-old can be re-integrated into the squad.

The bosses at the Säbener Straße know this, and a hardline is very much a negotiation tactic. Furthermore, they want to press Barca hard to accept a deal. The Catalans will have to pay at least €50 million, and because of Barcelona’s financial situation, Bayern is unlikely to accept any structured or bonus-heavy deals—in fact, the German champions want the lump sum in one go.

Should the Lewandowski deal go ahead, Bayern will be looking for a successor. The market for number 9s is, however, problematic. One candidate was Darwin Núñez, who recently joined Liverpool. Another is Sébastien Haller, the Ivorian national team player who has already agreed on terms with Bayern’s competitor Borussia Dortmund and will be presented in July. Finally, Sasa Kalajdzic is considered a backup rather than a full-time starter.

In the short-term, newly signed Sadio Mané is expected to fill that void. The problem with the Senegalese forward is that he is not a traditional number 9 and, despite being a prolific forward, will not be able to match Lewandowski’s goalscoring output right away.

Short-term, Bayern head coach Julian Nagelsmann seems to be happy to start a flexible attack with three natural wingers—Mané, Kingsley Coman, Serge Gnabry, and Leroy Sané. Long-term, there cannot be a future with a traditional number 9.

That is where Ekitie comes in. The 20-year-old French striker has already agreed on personal terms with Newcastle, and the Premier
PINC
League club has come to terms with his club Stade Reims. But that deal has now been stalled for weeks, and increasingly it appears that the highly talented forward could be signing elsewhere, with Bayern being one of the candidates.

Signing Ekitike, in fact, is seen as the sort of visionary transfer that could aid the club for the coming decade. There are, however, some doubts.

The $30.8 million rated forward would require an investment above his market value of at least $40 million. Then there is his recent injury history—Ekitike missed ten Ligue 1 games with a hamstring injury this season.

When he played, he was a force. The forward managed ten goals and four assists in just 24 Ligue 1 games this season—scoring every 128 minutes. Ekitike’s 0.64 goals per 90 minutes are, of course, a significant drop from Lewandowski’s 1 goal per 90 minutes scored for Bayern last season—but the Frenchman is 20.

Ekitike, in fact, had a higher goal conversion (34.375 vs. 26.027) than Lewandowski and managed to have a higher percentage of shots on target (62.5% to 54.34%). Ekitike is also better in one-v-one situations both in the number of dribbles attempted but also in the number of dribbles completed successfully.

Naturally, those numbers have to be taken with a grain of salt. Ekitike is 20 and has only just completed his first-ever professional season. Furthermore, Lewandowski—together with Karim Benzema—is the best number 9 on the planet. Still, the numbers show that Ekitike has enormous upside and underline why the Rekordmeister is seriously considering him as a potential signing this summer.

Manuel Veth is the host of the Bundesliga Gegenpressing Podcast and the Area Manager USA at Transfermarkt. He has also been published in the Guardian, Newsweek, Howler, Pro Soccer USA, and several other outlets. Follow him on Twitter: @ManuelVeth

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Memorandum on the Partnership for Global Infrastructure and Investment – The White House

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MEMORANDUM FOR THE HEADS OF EXECUTIVE DEPARTMENTS AND AGENCIES

SUBJECT:    Partnership for Global Infrastructure and Investment 

By the authority vested in me as President by the Constitution and the laws of the United States of America, and to establish my Administration’s policy and approach to executing the Partnership for Global Infrastructure and Investment (PGII), it is hereby ordered as follows:

Section 1.  Policy.  Infrastructure is critical to driving a society’s productivity and prosperity.  When done well, infrastructure connects workers to good jobs; allows businesses to grow and thrive; facilitates the delivery of vital services; creates opportunities for all segments of society, including underserved communities; moves goods to markets; enables rapid information-sharing and communication; protects societies from the effects of climate change and public health crises or other emergencies; and supports global connection among nations.  Infrastructure comes in many forms and sizes, from the large-scale energy systems that power inclusive economies, to the local healthcare networks that contribute to global health security, to the range of innovative infrastructure developed through investments from financial institutions and small- and medium-sized enterprises.  My Administration is making an urgent, once-in-a-generation investment in domestic infrastructure that will create jobs, help address the climate crisis, and help the Nation recover from the coronavirus disease 2019 (COVID-19) pandemic –– and the same focus is needed around the globe. 

Internationally, infrastructure has long been underfunded, with over $40 trillion in estimated need in the developing world –– a need that will only increase with the climate crisis and population growth.  Many low- and middle-income countries lack adequate access to high-quality financing that meets their long-term infrastructure investment needs.  Too often, financing options lack transparency, fuel corruption and poor governance, and create unsustainable debt burdens, often leading to projects that exploit, rather than empower, workers; exacerbate challenges faced by vulnerable populations, such as forced displacement; degrade natural resources and the environment; threaten economic stability; undermine gender equality and human rights; and put insufficient focus on cybersecurity best practices — a failure that can contribute to vulnerable information and communications technology networks.

The underinvestment in infrastructure is not just financial, but also technical.  Delivering high-quality infrastructure in low- and middle-income countries must include helping to establish and improve the necessary institutional and policy frameworks, regulatory environment, and human capacity to ensure the sustainable delivery of services to communities; defining strong engineering, environmental, social, governance, and labor standards; and structuring projects to attract private investment.  Through the PGII, the United States and like-minded partners will emphasize high-standards and quality investments in resilient infrastructure that will drive job creation, safeguard against corruption, guarantee respect for workers’ organizations and collective bargaining as allowed by national law or similar mechanisms, support inclusive economic recovery, address risks of environmental degradation, promote robust cybersecurity, promote skills transfer, and protect American economic prosperity and national security.  The PGII will also advance values-driven infrastructure development that is carried out in a transparent and sustainable manner — financially, environmentally, and socially — to lead to better outcomes for recipient countries and communities.

There is bipartisan support for international infrastructure development.  The Congress passed the Better Utilization of Investments Leading to Development Act of 2018 (BUILD Act) (Division F of Public Law 115-254, 132 Stat. 3485) with bipartisan support to mobilize private-sector dollars to support economic development in low- and middle income countries, which can include support for projects to build infrastructure, creating first-time access to electricity, starting businesses, and creating jobs.  The BUILD Act institutionalized the United States’ commitment to private sector–funded development by establishing the United States International Development Finance Corporation (DFC), authorized a higher exposure cap for the DFC than the exposure cap for the former Overseas Private Investment Corporation, and provided new tools to engage entrepreneurs and investors to help low- and middle-income countries access private resources to generate economic growth.  These investments help ensure that our partners are stronger, create opportunities for people around the world, and reduce the need for future United States foreign aid.

In a similar spirit, in 2018 the Congress passed the AGOA and MCA Modernization Act (Public Law 115-167, 132 Stat. 1276), authorizing the Millennium Challenge Corporation (MCC) to make concurrent regional compacts under specified conditions, which can include investments in regional infrastructure.  This new authority builds on the MCC’s record of delivering complex infrastructure projects that result in the delivery of vital services for communities and sustainable, inclusive economic growth.  In addition, recognizing the need for access to high-quality, fair, and transparent financing for United States exporters and foreign buyers, the Congress also reauthorized the Export-Import Bank of the United States (EXIM) for 7 years in 2019.  The EXIM’s reauthorization legislation also took steps to advance American leadership in transformational exports, which can include support for goods and services necessary for open, secure, reliable, and interoperable information and communications technology.

The United States and its partners have a long history of providing high-quality financing and technical support for infrastructure projects throughout the world.  However, the lack of a comprehensive approach for coordinating infrastructure investments with like-minded partners often leads to inefficiencies and missed opportunities for coordinated investments to deliver at scale.  Greater flexibility, speed, and resources, combined with expanded internal coordination within the United States Government, will provide opportunities for the United States Government and United States companies to better meet the infrastructure needs of low- and middle-income countries around the world.  At the same time, greater coordination with G7 and other like-minded partners will increase efficiency and catalyze new financing to advance a shared vision of values driven, high-quality, and sustainable infrastructure around the world.

Four key priorities relating to infrastructure will be especially critical for robust development in the coming decades:  climate and energy security, digital connectivity, health and health security, and gender equality and equity.  Economic prosperity and competitiveness will largely be driven by how well countries harness their digital and technology sectors and transition to clean energy to provide environmentally sustainable and broadly shared, inclusive growth for their people.  Countries not only will need new and retrofitted infrastructure, secure clean energy supply chains, and secure access to critical minerals and metals to facilitate energy access and transitions to clean energy, but also will need significant investments in infrastructure to make communities more resilient to diverse threats, from pandemics to malicious cyber actors, to the increasing effects of climate change.  Further, the COVID-19 pandemic has highlighted the unequal infrastructure needs in the developing world and has disproportionately affected low- and middle-income countries and regions, particularly with respect to the health sector.  In the developing world, the pandemic has also set back the economic participation of women and members of underserved communities and has reversed decades of progress toward ending poverty, with global extreme poverty rising for the first time in more than 20 years due to COVID 19.  The pandemic has highlighted the need for expanded investments in and high-quality financing for strengthened health systems to both fight the current pandemic and prepare for future health crises.

It is therefore the policy of the United States to catalyze international infrastructure financing and development through the PGII, which is designed to offer low- and middle-income countries a comprehensive, transparent, values-driven financing choice for infrastructure development to advance climate and energy security, digital connectivity, health and health security, and gender equality and equity priorities.  The PGII will mobilize public and private resources to meet key infrastructure needs, while enhancing American competitiveness in international infrastructure development and creating good jobs at home and abroad.  In this effort, the United States is working in close partnership with G7 and other like-minded partners toward infrastructure financing and infrastructure development that are sustainable, clean, resilient, inclusive, and transparent, and that adhere to high standards.

Sec. 2.  Approach.  In order to meet the enormous infrastructure needs in the developing world, a new approach to international infrastructure development that emphasizes high-standards investment is needed.  To meet this challenge and seize this opportunity, the PGII should:

        (a)  partner with low- and middle-income countries to finance infrastructure across key sectors that advances the four key priorities critical to sustainable, inclusive growth:  climate and energy security, digital connectivity, health and health security, and gender equality and equity;

        (b)  promote the execution of projects in a timely fashion in consultation and partnership with host countries and local stakeholders to meet their priority needs and opportunities, balancing both short- and longer-term priorities;

        (c)  pursue the dual goals of advancing prosperity and surmounting global challenges, including the climate crisis, through the development of clean, climate-resilient infrastructure that drives job creation, accelerates clean energy innovation, and supports inclusive economic recovery; 

        (d)  support the policy and institutional reforms that are key to creating the conditions and capacity for sound projects and lasting results and to attracting private financing;

        (e)  boost the competitiveness of the United States by supporting businesses, including small- and medium-sized enterprises in overseas infrastructure and technology development, thereby creating jobs and economic growth here at home;

        (f)  advance transparency, accountability, and performance metrics to allow assessment of whether investments and projects deliver results and are responsive to country needs, are financially sound, and meet a high standard;

        (g)  mobilize private capital from both the United States private sector and the private sector in partner countries; 

        (h)  build upon relationships with international financial institutions, including the multilateral development banks (MDBs), to mobilize capital;

        (i)  focus on projects that can attract complementary private-sector financing and catalyze additional market activity to multiply the positive impact on economies and communities; 
        (j)  coordinate sources of bilateral and multilateral development finance to maximize the ability to meet infrastructure needs and facilitate the implementation of high standards for infrastructure investment;

        (k)  uphold high standards for infrastructure investments and procurement, which safeguard against bribery and other forms of corruption, better address climate risks and risks of environmental degradation, promote skills transfer, generate good jobs, mitigate risks to vulnerable populations, and promote long-term economic and social benefits for economies and communities; and

        (l)  align G7 and other like-minded partners to coordinate our respective approaches, investment criteria, expertise, and resources on infrastructure to advance a common vision and better meet the needs of low- and middle-income countries and regions.

Sec. 3.  Execution.  (a)  A whole-of-government approach is necessary to meet the challenge of international infrastructure development, with executive departments and agencies (agencies) working together with like minded partners.  The Special Presidential Coordinator for the Partnership for Global Infrastructure and Investment shall be responsible for overseeing the whole-of-government execution of these efforts and serving as the central node for United States coordination among the G7, as well as with other like-minded partners, the private sector, and other external actors.  While specific lines of effort and initiatives may each have agency leads, such as on sourcing critical minerals or identifying trusted 5G and 6G vendors, whole-of-government policies should be addressed through the Coordinator.

        (b)  Agencies shall, consistent with applicable law and available appropriations, prioritize support for the PGII and make strategic investments across the PGII’s key priorities of climate and energy security, digital connectivity, health and health security, and gender equality and equity.

        (c)  The PGII shall be executed through the following key implementation efforts:

                (i)     The Assistant to the President for National Security Affairs (APNSA), through the interagency process identified in National Security Memorandum 2 of February 4, 2021 (Renewing the National Security Council System) (NSM-2), shall submit a report to the President within 180 days of the date of this memorandum.  The report shall include recommendations on United States Government actions to boost the competitiveness of the United States in international infrastructure development, and to improve coordination on international infrastructure development across relevant agencies.

                (ii)    The Secretary of State, the Secretary of the Treasury, the Secretary of the Interior, the Secretary of Commerce, the Secretary of Labor, the Secretary of Health and Human Services, the Secretary of Transportation, the Secretary of Energy, the Administrator of the United States Agency for International Development (USAID), and the heads of other relevant agencies shall prioritize programming consistent with the policy and approach described in sections 1 and 2 of this memorandum to support timely delivery of international infrastructure development, particularly across the PGII’s four key priorities, as appropriate and consistent with their respective authorities.  The Chief Executive Officer (CEO) of MCC, the CEO of DFC, the President of EXIM, the Director of the Trade and Development Agency (TDA), and the heads of other relevant independent agencies are encouraged to follow this same line of effort, as appropriate and consistent with their respective authorities.

                (iii)   The Secretary of State shall direct Chiefs of Mission to use all appropriate tools and to develop coordination mechanisms –– including through Embassy Deal Teams –– to address host country strategic infrastructure needs within the PGII’s four key priority areas.

                (iv)    The Secretary of State and the Secretary of Commerce, in consultation with the Secretary of Health and Human Services, the Secretary of Energy, the Administrator of USAID, the CEO of MCC, the CEO of DFC, the President of EXIM, and the Special Presidential Coordinator, shall develop a strategy for using Embassy Deal Teams to identify potential priority infrastructure projects for the PGII and refer promising opportunities to relevant agencies for consideration, based on each agency’s strengths and authorities.

                (v)     The Secretary of State, through the Special Presidential Coordinator and in consultation with the heads of other relevant agencies, shall coordinate diplomatic engagements to expand the PGII beyond the G7 to bring greater resources and opportunities for partnership.

                (vi)    The Secretary of State, through the Special Presidential Coordinator and in consultation with the Secretary of the Treasury, the Secretary of Commerce, the Secretary of Labor, the Secretary of Health and Human Services, the Secretary of Transportation, the Administrator of the Environmental Protection Agency, the Administrator of USAID, the CEO of MCC, and the CEO of DFC, shall lead interagency efforts regarding international coordination on infrastructure development standards and metrics, including on labor and environment, and certification mechanisms, including through the Blue Dot Network.

                (vii)   The Secretary of Commerce, in consultation with the Administrator of the Small Business Administration, the President of EXIM, the Director of TDA, and the Special Presidential Coordinator, shall develop and implement a strategy to boost the competitiveness of the United States and promote the use of United States equipment and services in international infrastructure development.

                (viii)  The Secretary of the Treasury, in consultation with the Secretary of State, the CEO of MCC, the CEO of DFC, and the Special Presidential Coordinator, shall develop and implement a strategy to catalyze private-sector investment and support low- and middle income countries across the PGII’s four key priority areas.

                (ix)    The Secretary of the Treasury, in consultation with the Secretary of State, the Secretary of Commerce, the Secretary of Health and Human Services, the Administrator of USAID, and the Special Presidential Coordinator shall develop a plan for engaging the MDBs to foster high-quality infrastructure investment and increased private-capital mobilization for low- and middle-income countries, and shall coordinate with like-minded partners in the plan’s execution.  The CEO of DFC, in consultation with the Secretary of State, the Secretary of the Treasury, the Administrator of USAID, and the Special Presidential Coordinator, is encouraged to develop a plan to enhance engagement with national and international development finance institutions to increase private-capital mobilization.

                (x)     The Secretary of Transportation, in consultation with the heads of other relevant agencies, shall develop and implement a strategy to promote high-quality, sustainable, and resilient transportation infrastructure in low- and middle-income countries, including through the launch of a comprehensive toolkit for national, subnational, and multilateral partners that emphasizes best practices in planning, finance, project delivery, safety, and maintenance.

                (xi)    The APNSA, through the interagency process identified in NSM-2 and in coordination with the Director of the Office of Management and Budget, shall identify potential legislative and administrative actions that could improve the ability of United States economic development and assistance, development finance, and export credit tools to meet international infrastructure development needs.

                (xii)   The APNSA, through the interagency process identified in NSM-2, shall lead biannual reviews to monitor the progress, metrics, and outcomes of the PGII’s investments and projects; identify strategic opportunities across the PGII’s four key priorities; and ensure that the execution of the PGII aligns with, and supports, broader strategic United States national security and economic objectives and values, including by supporting United States companies in international infrastructure development.

Sec. 4.  Definition.  For purposes of this memorandum, “agency” means any authority of the United States that is an “agency” under 44 U.S.C. 3502(1), other than one considered to be an independent regulatory agency, as defined in 44 U.S.C. 3502(5).  “Agency” also means any component of the Executive Office of the President.

Sec. 5.  General Provisions.  (a)  Nothing in this memorandum shall be construed to impair or otherwise affect:

                (i)   the authority granted by law to an executive department or agency, or the head thereof; or

                (ii)  the functions of the Director of the Office of Management and Budget relating to budgetary, administrative, or legislative proposals.

        (b)  This memorandum shall be implemented consistent with applicable law and subject to the availability of appropriations.

        (c)  This memorandum is not intended to, and does not, create any right or benefit, substantive or procedural, enforceable at law or in equity by any party against the United States, its departments, agencies, or entities, its officers, employees, or agents, or any other person.

        (d)  The Secretary of State is authorized and directed to publish this memorandum in the Federal Register.

                        JOSEPH R. BIDEN JR.

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