âTo sum up what distinguishes the United States in a nutshell: Itâs the First Amendment,â said Steven Aftergood, the director of the Project on Government Secrecy at the Federation of American Scientists. âThe concept of a free press has been integral to the American idea since its inception. Thatâs not true even of other democracies. The press here even has the right to be irresponsible, which it sometimes is.â
The contrast with Britain, despite the shared democratic heritage, is particularly stark. Instead of the First Amendment, the British have the Official Secrets Act, which allows the government to ban in advance the publication of government secrets and prescribes punishments not just for leakers, but also for the journalists who publish the information.
Despite an unprecedented string of prosecutions for leaks under the Obama administration and a pledge on Thursday by Mr. Trumpâs attorney general, Jeff Sessions, to end âthese rampant leaks that undermine our national security,â unauthorized disclosures of secrets are far more common in Washington than in London.
âIâm trying to think of a scandal over a leak from the intelligence service here, and I canât think of one,â said John Lloyd, a veteran British journalist and a founder of the Reuters Institute for the Study of Journalism at Oxford University. âThe culture of âyou donât need to know thisâ hangs around in the U.K.â
He added that the F.B.I., the C.I.A., and in recent years even the National Security Agency had been far more open and involved in the political fray than their buttoned-up counterparts in Britain, known respectively as MI5, MI6 and Government Communications Headquarters.
Mr. Lloyd said the countersecrecy culture in the United States was shaped not only by the First Amendment,…