Office of Suspension and Debarment

Email: jsmith@worldbank.org

Jamieson A. Smith, a United States national, is the Chief Suspension and Debarment Officer (the “SDO”) for the World Bank.  Mr. Smith heads the World Bank’s Office of Suspension and Debarment (“OSD”), which is an independent unit within the Bank and is the first tier of the Bank’s two-tiered adjudicative sanctions system.  The SDO is tasked with impartially reviewing accusations of fraud, corruption, and collusion against respondent firms and individuals brought by the Bank’s Integrity Vice Presidency (“INT”).  For each case, Mr. Smith determines whether there is sufficient evidence to suspend the contracting eligibility of the respondents.  In deciding on cases, the SDO does not take instructions from any other person or unit. Mr. Smith has spoken on multilateral institutions’ approach to anti-corruption at various domestic and international conferences, including venues in Austria, Brazil, Denmark, Côte d’Ivoire, France, Italy, South Africa, South Korea, Singapore, and the United Kingdom.  Prior to his service at the Bank, Mr. Smith was an attorney in private practice, where he represented corporations and individuals in a wide variety of white collar criminal and regulatory matters, including alleged violations of the U.S. Foreign Corrupt Practices Act.  He has conducted internal investigations in China, Egypt, Indonesia, Brazil, Croatia, Italy and Czechia, and also advised clients with respect to compliance and corporate governance issues.  Mr. Smith also teaches a course on international anti-corruption efforts as an Adjunct Professor at Georgetown University Law Center. Mr. Smith received his A.B. from Duke University, and his J.D. from Duke University’s School of Law, where he was a member of Law & Contemporary Problems.  He also earned his M.A. in American Legal History from the University of Virginia. 

Email: amanea@worldbank.org

Alexandra Manea is Senior Counsel (Sanctions) in OSD, where she assists the Chief Suspension and Debarment Officer with the review and disposition of sanctions cases, and advises on institutional anti-corruption policy.  Previously, Alexandra worked in the Bank’s Legal Vice Presidency on governance projects in the extractive industries, with a focus on enhancing transparency and mainstreaming anti-corruption provisions in the mining legal frameworks across Africa. Before joining the Bank, Alexandra practised as a business attorney in Romania and as a legal consultant for Romania’s National Anti-Corruption Strategy. She has authored numerous papers on anti-corruption efforts across jurisdictions and corporate liability for corruption offenses. With a strong belief that integrity education is one of the key solutions to sustainably reduce corruption, she speaks regularly on integrity and anti-corruption topics at various institutions, including the International Anti-Corruption Academy in Austria. A native of Romania, Alexandra holds a Ph.D. in International Anti-Corruption Law, completed in a joint program in Israel, Romania, and the U.S. with a Fulbright scholarship.  She serves as a board member of the World Bank Group-International Monetary Fund Fulbright Network and as a mentor for the American Society of International Law’s Women in International Law Group.

Email : gklarson@worldbank.org

Gaukhar Larson is Senior Counsel (Sanctions) in OSD, where she works with the Chief Suspension and Debarment Officer to review sanctions cases and determine whether to suspend the contracting eligibility of respondent firms and individuals. Prior to joining OSD, Ms. Larson worked in the International Finance Corporation’s Business Risk and Compliance Department on integrity, regulatory risk, tax and compliance matters. Earlier, she worked with the World Bank’s Financial Market Integrity Unit and Stolen Asset Recovery Initiative (StAR) on anti-corruption and financial disclosure matters.  Before joining the World Bank Group in 2014, Ms. Larson worked for the United Nations Office on Drugs and Crime, the Organization for Security and Co-operation in Europe, and two international law firms.  As an attorney in private practice, she investigated and litigated complex international fraud matters and advised local and international clients on regulatory and compliance matters. A native of Kazakhstan, Ms. Larson earned an LL.M. in Securities and Financial Regulation from Georgetown University Law Center, an LL.M. from The George Washington University Law School, and an LL.B. in International Law, with highest honors, from Kazakh National University.

Email: cliu14@worldbank.org

Chang Liu is Counsel (Sanctions) in the Office of Suspension and Debarment (OSD), where he assists the Chief Suspension and Debarment Officer in reviewing sanctions cases to determine whether to suspend respondents’ eligibility for World Bank-financed contracts. Before joining the World Bank, Mr. Liu practiced at two international law firms and served as a law clerk for the Honorable John G. Koeltl of the U.S. District Court for the Southern District of New York. His private practice experience includes advising clients on white-collar defense, internal investigations, and complex cross-border commercial disputes. Mr. Liu speaks regularly on the World Bank’s Sanctions System and other integrity and anti-corruption related topics at various institutions and conferences. A native of China, he earned a B.S., with honors, in Economics and Urban Studies from Trinity College, Connecticut, and a J.D., cum laude, from Harvard Law School, where he served as Executive Editor of the Harvard International Law Journal.

Email : amontoya@worldbank.org

Adri Montoya is the Program Assistant at OSD. Ms. Montoya supports the unit with administrative duties, case management, and event planning. Prior to joining OSD, Ms. Montoya was the Assistant Director of the Donor Services department at CAF America. Earlier in her career, Ms. Montoya was an intern at the Embassy of the Plurinational State of Bolivia in Washington, D.C. As an undergraduate student, Ms. Montoya interned for Blue Ridge Legal Services in Harrisonburg, VA. A native of Bolivia, Ms. Montoya earned a B.A. in Political Science with a minor in Legal Spanish from James Madison University.

Email : ssafarova@worldbank.org

Shukrana Safarova is a Program Assistant at OSD, where she manages case adminstration, handles various administrative duties, and coordinates event planning. Ms. Safarova earned her B.A. Political Science, summa cum laude, from the University of the District of Columbia. A native of Azerbaijan, she also gained valuable experience as a legal intern at a litigation-oriented law firm during her college years. 

Email : htran28@worldbank.org

Hai Anh Tran is a Legal Consultant in OSD, where she assists in the review and disposition of sanction cases. A native of Vietnam, Ms.Tran earned an LL.M. in Government Procurement and Environmental Law from The George Washington University Law School, an LL.M. in International Law, summa cum laude, from Transnational Law and Business University in South Korea, and an LL.B. in Hanoi Law University in Vietnam.

Email : ykim30@worldbank.org

Yoonhye Kim is a Legal Consultant in OSD, where she assists the staff attorneys in reviewing sanctions cases. Previously, she worked with the World Bank's Women, Business, and the Law project, an international law firm, and the Permanent Mission of the Republic of Korea to the United Nations Office and other International Organizations in Geneva, Switzerland. A native of the Republic of Korea, Ms. Kim received her B.A. in International Studies from Boston College and her J.D. concentration in International Business Law from The George Washington Law School. During law school, she served as an Articles Editor for the Federal Circuit Bar Journal.  

Email : asilva9@worldbank.org

Prior to joining OSD, Mr. Silva has worked with law firms in Washington D.C. and New York, and a national non-profit organization. A Manhattan native, Mr. Silva graduated from Fordham University, summa cum laude, earning a B.A. in Political Science, with a double minor in Mandarin Chinese and Peace & Justice Studies. Currently, Mr. Silva is pursuing his J.D. at The George Washington Law School, where he participates in the student advisor program, serves as a Writing Fellow, and is a member of the George Washington International Law Review.

Email: afulling@worldbank.org

Alexander Fulling joined OSD as a legal intern in 2025. Prior to matriculating at The George Washington University Law School, he was a consultant to the Office of Foreign Assistance at the U.S. Department of State. At GW, he is an Associate on The George Washington Journal of Energy & Environmental Law (JEEL) and a contributor to the International Law and Policy Brief (ILPB). Mr. Fulling holds a bachelor’s degree in Political Science & International Affairs from Wake Forest University and is positioned to graduate from GW with his J.D. in 2026. He is a native of the U.S. but was raised abroad in the United Kingdom and in the Russian Federation.