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World Bank Group Sanctions Board

  • The World Bank Group Sanctions Board, composed of seven (7) external judges, is an independent administrative tribunal that serves as the final decision-maker in all contested cases of sanctionable misconduct occurring in development projects financed by the World Bank Group (WBG). With the support of a dedicated Secretariat, the Sanctions Board functions as the second tier of the WBG sanctions system and issues final decisions on appeals of determinations reached at the first tier.


    Highlights





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    Background and Mission: The World Bank Group (WBG) Sanctions Board is an independent administrative tribunal that functions as the second and final tier of the WBG sanctions system and issues non-appealable decisions in all contested cases of sanctionable misconduct in development projects financed by the WBG. Under the Sanctions Board Statute, the Sanctions Board consists of seven (7) members all external to the World Bank Group: three (3) members appointed by the Executive Directors, who must not currently hold any appointment to the staff of the WBG and shall be familiar with procurement matters, law, dispute resolution mechanisms, or operations of development institutions; and two (2) members appointed for each of International Finance Corporation (IFC) and Multilateral Investment Guarantee Agency (MIGA) by the Executive Directors, who must not currently hold any appointment to the staff of the WBG and shall be familiar with private sector cross-border lending and equity investments (for IFC Projects) or non-commercial guarantee operations (for MIGA Projects). Ms. Maria Vicien Milburn currently chairs the Sanctions Board. Information on the Sanctions Board's membership is available here.

    Process: The Sanctions Board carries out a full de novo review in each contested case. It is not bound by the Suspension and Debarment Officer's or Evaluations Officers' recommendation. An administrative hearing may be held by the Sanctions Board either upon a party's request or at the discretion of the Sanctions Board Chair. In its deliberations, the Sanctions Board considers INT's allegations and evidence as attached to the Notice of Sanctions Proceedings; the respondent's arguments and evidence submitted in response to INT's allegations and evidence; INT's reply brief; the parties' presentations at a hearing, if applicable; and any other materials contained in the record. After completing its review, the Sanctions Board determines whether it is "more likely than not" that the respondent engaged in a sanctionable practice. If so, the Sanctions Board imposes one or more appropriate sanctions from a range of possible sanctions including, (i) reprimand, (ii) conditional non-debarment, (iii) debarment, (iv) debarment with conditional release, and (v) restitution or remedy, which may extend to a respondent's affiliates, successors and assigns. Debarments of over one (1) year are also subject to mutual enforcement by other multilateral development banks (MDBs). Additional details and guidance on this process are available here.

    Outcomes: The decisions of the Sanctions Board are final and non-appealable. In each of its decisions, the Sanctions Board addresses all procedural issues in dispute, the respondent's liability for the alleged misconduct, the specific sanction imposed, if any, and the scope and basis of that sanction. The decisions are circulated to the parties and/or their counsel immediately upon issuance and to other stakeholders at the WBG for their information. Decisions issued beginning in 2011 are also published in full and available here. Although decisions issued in earlier cases are not published in full, their holdings are available in the Sanctions Board's Law Digest, issued in 2011. The Sanctions Board's published case law provides a growing body of jurisprudence and resource for parties and other international organizations. Since 2001, more than 600 firms and individuals have been publicly sanctioned by the WBG (visit www.worldbank.org/debarr for the full current list of sanctioned firms and individuals).






    Contact Sanctions Board

    The World Bank 1818 H Street, N.W., MSN G 5‐503, Washington, D.C. 20433, U.S.A.
    sanctionsboard@worldbank.org
  • World Bank Group Sanctions Documents

    WBG Policy: Sanctions for Fraud and Corruption (issued June 13, 2016)

    This Policy mandates an administrative system for adjudicating allegations of fraud and corruption in connection with World Bank Group financing or guarantee operations and imposing sanctions therefor; and identifies practices subject to sanction and possible forms of sanctions.

    WBG Policy: Statute of the Sanctions Board (issued October 18, 2016)

    This Policy sets out the role, composition, competence, and responsibilities of the World Bank Group Sanctions Board.

    Prior versions: September 15, 2010 | As amended February 17, 2009

    WBG Procedure: Selection and Appointment of WBG Sanctions Board Members (issued October 10, 2019)

    This Procedure sets forth the process by which Sanctions Board Members are selected and appointed.

    World Bank Group Sanctioning Guidelines (issued January 1, 2011)

    This document provides guidance to those who have the discretion to impose sanctions on  behalf of the World Bank Group as to the considerations that the World Bank Group believes are relevant to any sanctioning decision.

    Summary of Integrity Compliance Guidelines

     

    IBRD and IDA Sanctions Documents

    Bank Procedure: Sanctions Proceedings and Settlements in Bank Financed Projects (issued June 28, 2016)

    This Procedure, commonly referred to as the “Sanctions Procedures,” sets out the procedures to be followed in the administrative process by which the Bank determines whether or not to sanction parties alleged to have engaged in a sanctionable practice in connection with a Bank-financed project.

    Prior versions of the Sanctions Procedures are available here: April 15, 2012 | January 1, 2011 (as amended July 8, 2011) | September 15, 2010 | May 11, 2009 (as amended June 25, 2010) | October 15, 2006

    Bank Directive: Sanctions for Fraud and Corruption in Bank Financed Projects (issued June 28, 2016)

    This Directive sets out the institutional and normative architecture of the sanctions system; determines the jurisdiction of the sanctions system; and provides directions on the application of sanctions.

     

    IFC, MIGA, and Private Sector Sanctions Documents

    IFC Sanctions Procedures

    This Procedures sets out the administrative process to be followed in cases involving alleged sanctionable practices, such as fraudulent, corrupt, collusive, coercive and/or obstructive practices in connection with an IFC Project and operations, non-responsibility of a vendor in procurement, or arising from a violation of a material term of the World Bank Group Voluntary Disclosure Program.

    Prior version: January 1, 2007

    MIGA Sanctions Procedures

    This Procedures sets out the administrative process to be followed in cases involving alleged sanctionable practices, such as fraudulent, corrupt, collusive, coercive and/or obstructive practices in connection with projects guaranteed by MIGA and projects in which MIGA has offered technical assistance, or arising from a violation of a material term of the World Bank Group Voluntary Disclosure Program.

    Prior version: October 15, 2006

    World Bank Private Sector Procedures

    This Procedures sets out the administrative process to be followed in cases involving alleged sanctionable practices, such as fraudulent, corrupt, collusive, coercive and/or obstructive practices in connection with World Bank guarantee and carbon finance projects, or arising from a violation of a material term of the World Bank Group Voluntary Disclosure Program.

    Prior version: 2006

     

    Procurement Regulations and Anti-Corruption Guidelines

    World Bank Procurement Regulations for Investment Project Financing Borrowers (for projects after July 1, 2016) -- Click here for previous versions of the Procurement Guidelines and Consultant Guidelines (for projects before July 1, 2016)

    Guidelines on Preventing and Combating Fraud and Corruption in Projects Financed by IBRD Loans and IDA Credits and Grants (July 1, 2016) (Also known as "Anti-Corruption Guidelines")

    Prior versions: January 1, 2011 |  October 15, 2006

    User-Friendly version of the Anti-Corruption Guidelines

    Brazilian Portuguese | Arabic | Spanish | Portuguese | Chinese | Russian | French

     

    Background and Reference Documents

    Advisory Opinion on Certain Issues Arising in Connection with Recent Sanctions Cases (No. 2010/1) (November 15, 2010; released to public by the World Bank Legal Vice Presidency in June 2013)

    The World Bank Group’s Sanctions Regime: Information Note

    World Bank Group Sanctions Regime - An Overview (October 8, 2010) 

    Report Concerning the Debarment Processes of the World Bank - Thornburgh et al. (August 14, 2002)

    Terms and Conditions of the World Bank’s Voluntary Disclosure Program - VDP (August 16, 2006)

    Agreement for Mutual Enforcement of Debarment Decisions (April 9, 2010) 





    Contact Sanctions Board

    The World Bank 1818 H Street, N.W., MSN G 5‐503, Washington, D.C. 20433, U.S.A.
    sanctionsboard@worldbank.org
  • Sanctions Board Decisions

    Consistent with the World Bank Group's commitment to transparency, the Sanctions Board is a leader among Multilateral Development Banks (MDBs) as the only sanctions appeals body that publishes fully-reasoned decisions in all types of appeals that it reviews.

    Sanctions Board decisions are final and non-appealable. In each of its decisions, the Sanctions Board addresses all procedural issues in dispute, the respondents’ liability for the alleged misconduct, the specific sanction imposed, if any, and the scope and basis of that sanction. The decisions are circulated to the parties and/or their counsel immediately upon issuance and to other stakeholders at the Bank for their information. ​

    The holdings in decisions issued between 2007 and 2011 were presented in the first edition of the Sanctions Board’s Law Digest, published in December 2011. The Second editition of the Sanctions Board's Law Digest reviews the Sanctions Board’s holdings in more than 100 decisions issued since 2007 and provides additional information on the work of the Sanctions Board to date. The many topics covered in this publication include assessment of various allegations of misconduct, factors that affect the choice of sanction, and the Sanctions Board’s treatment of various procedural issues and requests in the course of sanctions proceedings.

    For further information on the sanctions system, please refer to the Key Documents.


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    Sanctions Board Insights

    Sanctions Board Insights - February 2022

    The Sanctions Board's Newsletter shares updates about recent Sanctions Board membership changes, decisions, and select sanctions data.

    Sanctions Board Insights - September 2021

    This inaugural edition of the Sanctions Board's Newsletter shares updates about recent Sanctions Board membership changes, decisions, and select sanctions data. 

    World Bank Group Sanctions System Annual Report

    World Bank Group Sanctions System Annual Report (FY21)

    Prepared jointly by the World Bank Group’s Integrity Vice Presidency, Office of Suspension and Debarment, and Sanctions Board, the report illustrates how the institution’s sanctions system has worked in FY21 to meet the challenges and opportunities of an ever-changing global anticorruption landscape.

    World Bank Group Sanctions System Annual Report (FY20)

    The third joint Sanctions System Annual Report addresses the institution’s continued efforts to investigate and adjudicate allegations of misconduct in projects financed by the World Bank Group. This publication presents an overview of the sanctions system and its results as reported by the Sanctions Board, the Integrity Vice Presidency (INT), and the Office of Suspension and Debarment (OSD).

    World Bank Group Sanctions System Annual Report (FY19)

    This second joint Sanctions System Annual Report (FY19) addresses the WBG's continued efforts to investigate and adjudicate allegations of misconduct in projects financed by the institution. This publication presents an overview of the sanctions system and its results as reported by the WBG Sanctions Board, the Integrity Vice Presidency (INT), and the Offfice of Suspension and Debarment (OSD).

    World Bank Group Sanctions System Annual Report (FY18)

    This inaugural report is the result of efforts by the Integrity Vice Presidency (INT), the Office of Suspension and Debarment (OSD) and the Sanctions Board to prepare a joint overview of the Bank Group Sanctions System and its activities over the past year.

     

    Sanctions Board Law Digest

    Sanctions Board Law Digest (2019)

    The Sanctions Board Secretariat is pleased to announce the publication of the 2019 WBG Sanctions Board Law Digest. The Law Digest reviews the Sanctions Board’s holdings in more than 100 decisions issued since 2007 and provides additional information on the work of the Sanctions Board to date. The many topics covered in this publication include assessment of various allegations of misconduct, factors that affect the choice of sanction, and the Sanctions Board’s treatment of various procedural issues and requests in the course of sanctions proceedings.

    For further reference, the full text of Sanctions Board decisions in cases initiated on or after January 1, 2011, may be found here. A current listing of all sanctioned parties may be found at www.worldbank.org/debarr.

    Sanctions Board Law Digest (2011)

    The 2011 Law Digest summarizes for informational purposes the evolving case law of the Sanctions Board from its inception in 2007 through October 31, 2011. The Law Digest, as prepared by the Sanctions Board Secretariat and reviewed by Sanctions Board members, comprises two parts: Case Summaries and a Case Digest. The Case Summaries provide a brief synopsis of the allegations, outcome, and procedural framework for each case. The Case Digest entries illustrate the legal principles and considerations applied by the Sanctions Board based on the facts and circumstances presented in each case.

     

    Sanctions Board Secretariat Publication

    On January 31, 2022, the FCPA Blog published SBS's piece - Is debarment for fraud 'fair and appropriate'? The Sanctions Board Secretariat is continuing its role as a thought-leader in the anti-corruption space with the publication of a piece on the Sanctions Board's nuanced and predictable approach to selecting proportionate sanctions. This article specifically discusses the selection of sanctions in fraud cases, including whether debarment for fraud is fair and appropriate.

    On August 4, 2021, the FCPA Blog published SBS's piece - World Bank Sanctions Board proceedings can be fair, flexible...and fast. The articles discusses how the Sanctions Board has endeavored to be ever more agile and adaptive – including through holding hearings and resolving cases virtually during the Covid-19 pandemic and more.

    On December 15, 2020, the FCPA Blog published SBS's piece - A diverse World Bank Sanctions Board brings credibility and fairness. The article discusses how the Sanctions Board's diverse composition contributes to its effective decision-making and the credibility of the Sanctions System.

    On August 24, 2020, the FCPA Blog published SBS's piece - What we've learned at the World Bank Group about international cooperation. The article discusses the importance of international coordination in addressing corruption. 

     





    Contact Sanctions Board

    The World Bank 1818 H Street, N.W., MSN G 5‐503, Washington, D.C. 20433, U.S.A.
    sanctionsboard@worldbank.org
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    Mrs. Maria Vicien Milburn

    Sanctions Board Chair, World Bank Group

    Mrs. Maria Vicien Milburn, an Argentinian and Spanish national, has served on the World Bank Group Sanctions Board since July 2019. Mrs. Vicien Milburn has served for more than thirty-five years as an international lawyer in the United Nations System, holding such senior roles as General Counsel of UNESCO (2009-2014), and Director of the General Legal Division of the UN Office of Legal Affairs (2004-2009). In these roles, she oversaw all commercial contracting, directed the conduct of all litigation and arbitration, and advised on international treaties and conventions. Mrs. Vicien Milburn currently serves as a judge and arbitrator in the context of disputes of an international character. In 2017, she was designated on the list of panelists of the Dispute Settlement Body of the World Trade Organization (WTO). In 2018, she was appointed as Judge of the Administrative Tribunal of the European Bank for Reconstruction and Development (EBRD); and in 2020, as Judge of the Administrative Tribunal of the Inter-American Development Bank (IDB). She also acts as arbitrator in cases conducted under the auspices of the International Chamber of Commerce (ICC), the International Centre for Settlement of Investment Disputes (ICSID), and the Permanent Court of Arbitration (PCA). She is an observer to UNCITRAL Working Groups II and III on international arbitration, a member of the ICC Arbitration Commission, and an advisor to the Board of the Arbitration Court of Madrid. A graduate of the University of Buenos Aires Law School (1974) and Columbia University (LL.M., 1976), she is admitted to practice law in New York and Buenos Aires. The American Bar Association awarded her the 2013 Mayre Rasmussen Award for the Promotion of Women in International Law.

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    Mr. John Murphy

    Sanctions Board Member, IBRD/IDA

    Judge John Murphy, a South African national, has served on the World Bank Group Sanctions Board since July 2019. He is a Judge of Appeals of the United Nations Appeals Tribunal and served as its President from January 2018 to December 2018. He is also an Acting Judge of Appeals of the Labour Appeal Court of South Africa and was previously a Judge of the High Court of South Africa (Gauteng Division, Pretoria). Prior to that he served as a Judge of the Labour Court and was South Africa’s first Pensions Ombudsman (the Pension Funds Adjudicator) between 1997 and 2003. He has worked as an arbitrator and mediator for the Commission for Conciliation, Mediation and Arbitration and the Independent Mediation Service of South Africa and was an Associate Professor of Law and Head of the Department of Public Law at the University of the Western Cape. He has served on various statutory bodies in South Africa including the Council for Medical Schemes. In 2003-2004 he was the Presiding Judge in the Special Chamber of the Kosovo Supreme Court for Kosovo Trust Related Matters.

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    Ms. Rabab Yasseen

    Sanctions Board Member, IBRD/IDA

    Ms. Rabab Yasseen, a Swiss national, has served on the World Bank Group Sanctions Board since July 2019. Ms. Yasseen is a partner with the Geneva Law Firm MENTHA, and also serves as Deputy Judge to the Civil Courts in Geneva, Switzerland. She previously held positions in major Law Firms, as General legal counsel to the University of Geneva and as a consultant to the WTO/ITC. She has been acting as counsel / arbitrator (sole / chair / co-arbitrator) in both ad hoc and institutional arbitration proceedings under various rules. She was a member of the Ad Hoc Division of CAS to the XXXI Olympiad - the Rio 2016 Olympic Games. She is a member of several panels and associations, including the ICC arbitration commission where she was an active member of the task forces on “the revision of the ICC rules of arbitration”, on “States, State-entities and ICC arbitration”, on “the Emergency Arbitrator proceedings”, as well as the IBA task force drafting the “investor-State mediation rules”. She is a member of the ILA international Commercial Arbitration Committee. Ms. Yasseen is also a regular delegate to the UNCITRAL Commission and Working Group II and III sessions, including those on “transparency in treaty-based investor-State arbitration” (the transparency rules and the Mauritius Convention), on the “enforcement of settlement agreements” (the Singapore Convention) and the current sessions on “the investor-State dispute settlement reform”. She has co-authored both the ITC contractual and incorporated joint-venture model agreements and their user’s guide, published in the UNCTAD / WTO Trade Law series in Geneva. Ms. Yasseen holds degrees in Law, History and Literature from the University of Geneva, as well as an LL.M in international business law from King‘s College London. She is admitted to the Geneva bar and as a solicitor to the Supreme Court (England and Wales).

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    Mr. Cavinder Bull

    Sanctions Board Member, IFC

    Mr. Cavinder Bull, a Singapore national, has served on the World Bank Group Sanctions Board since October 2018. Mr. Bull practices at Drew & Napier LLC, one of the largest firms in Singapore, where he is the Chief Executive Officer. He has an active practice in complex litigation as well as in international arbitration where he acts both as counsel and as arbitrator in commercial and investor-state arbitrations. Mr. Bull is also Vice-President of the Singapore International Arbitration Centre (SIAC) Court of Arbitration and was the Deputy Chairman of SIAC from 2010 to 2017. He is also a member of the Governing Board of ICCA, Vice-President of the Asian Pacific Regional Arbitration Group and a member of the Asian Business Law Institute’s Advisory Board. Mr. Bull graduated with First Class Honors in law from Oxford University and holds a Masters-in-Law from Harvard Law School, which he attended on a Lee Kuan Yew Scholarship. Mr. Bull is admitted to the bars of Singapore, New York, and England & Wales. The Chief Justice of Singapore appointed him Senior Counsel in 2008, one of only a handful to have been appointed before the age of 40. 

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    Mrs. Adedoyin Rhodes-Vivour

    Sanctions Board Member, IFC

    Mrs. Adedoyin Rhodes-Vivour, a Nigerian national, has served on the World Bank Group Sanctions Board since November 2020. Mrs. Rhodes-Vivour, SAN, C.Arb has practiced law for nearly 40 years specializing in International Arbitration,  Commercial law , litigation and various forms of Alternative  Dispute Resolution. She is a graduate of the University of Lagos, Nigeria (LLB, LLM) and King’s College London, University of London (M.A in International Peace and Security with merit). Mrs Adedoyin is a British Chevening Scholar and awardee of the United States Information Services (USIS) Young African Leaders Programme (1990). She is a Fellow and Chartered Arbitrator of the Chartered Institute of Arbitrators United Kingdom. She is a CEDR [UK] Accredited Mediator.

    Mrs. Rhodes-Vivour is a practicing African International Arbitrator and  Senior Advocate of Nigeria. She was a former member of the Court of the Permanent Court of Arbitration (PCA) The Hague, The Netherlands. She is a member of the ICC International Court of Arbitration, ICC Arbitration & ADR Commission, member of the ICC Africa Commission and the International Commercial Arbitration Committee of the International Law Association.

    She acts as an arbitrator and counsel in both ad hoc and institutional arbitrations  and is listed on the Panel and Data base of Arbitrators of various leading international arbitration Institutions. She is recognized as one of the world’s  preeminent practitioners in the field. She is recognized in publications including Guide to the World’s Leading Commercial Arbitration Experts (Expert guides) and Who’s Who Legal. She is described as an arbitrator who “garners strong praise from market sources for her first-class practice” and is adjudged as “providing clients with a wealth of expertise as both arbitrator and counsel across the financial services and energy sectors”. She is recognized as one of the women Pioneers in dispute resolution in the 2nd Edition of Women Pioneers in Dispute Resolution published by the Deutsche Gesellschaftfur Internationale Zusammenarbeit (GIZ) GmbH, on behalf of the German Federal Ministry for Economic Cooperation and Development (BMZ), with the co-operation of ArbitralWomen.

    Mrs. Rhodes-Vivour is a Vice President of the LCIA African Users Council and member of the  Singapore International Arbitration Centre (SIAC) Users Council. She is the immediate past Chairperson, Chartered Institute of Arbitrators (CIArb) UK Nigeria Branch, Mrs. Rhodes-Vivour is a board member of the African Arbitration Association [AfAA]  She is an approved tutor of the Chartered Institute of Arbitrators (CIArb) and is a CIARB Regional Pathway Leader for Africa.

    Mrs. Rhodes-Vivour is a member of ArbitralWomen and Co-Chair of the Equal Representation in Arbitration [ERA] Pledge African Sub-committee.

    She is the author of the book “Commercial Arbitration Law and Practice in Nigeria through the cases” published by LexisNexis, South Africa.

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    Mr. Eduardo Zuleta

    Sanctions Board Member, MIGA

    Mr. Eduardo Zuleta, a Colombia national, has served on the World Bank Group Sanctions Board since November 2020. Mr. Zuleta serves as arbitrator in commercial and investment disputes, including annulment committees under the ICSID Convention. Mr. Zuleta presently serves as Vice President of the ICC Court of Arbitration. He was appointed in 2011 to the ICSID panel of arbitrators by the Chairman of the ICSID Administrative Council and was subsequently appointed as member of the ICSID panel of arbitrators in 2018 by the Republic of Colombia. Mr. Zuleta was co-Chair of the Arbitration Committee of the IBA where he led the amendments to the IBA Guidelines on Conflicts of Interest in International Arbitration and the adoption of the IBA Guidelines for Party Representation in International Arbitration. Mr. Zuleta is also a member of the Governing Board of ICCA, member of the Advisory Board of  the New York International Arbitration Center; past member of the court of arbitration of the LCIA and founder and past President of the Latin American Arbitration Association.

    Mr. Zuleta is listed as arbitrator in CIETAC, Hong Kong International Arbitration Center, Singapore International Arbitration Center and various arbitration centers in Latin America.  

    Mr. Zuleta holds a law degree of Universidad del Rosario, Bogotá, D.C., Colombia, where he graduated with honors, best student of class; a Master of Laws in Financial Law, by the same law school; and a Master, with merits, on commercial and investment arbitration, investment law and law of the treaties, with specialization in International Dispute Resolution, from University of London, Queen Mary.

    Mr. Zuleta is a partner at Zuleta Abogados Asociados. He was a partner in a Colombian law firm and a partner at Baker&Mckenzie where he had an extensive practice in M&A, project finance and international finance.

    Mr. Zuleta has written extensively on both commercial and investment arbitration and has been invited as lecturer and panelist to several law schools and professional for a worldwide. He is Adjunct Professor at Georgetown University Law Center.

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    Mr. Michael Ostrove

    Sanctions Board Member, MIGA

    Mr. Michael Ostrove, a United States and French dual national, has served on the World Bank Group Sanctions Board since December 2021. Mr. Ostrove is a partner in the DLA Piper law firm and is Global Co-Chair of their International Arbitration group. He also serves as a Vice-President of the ICC International Court of Arbitration. Admitted to both the Paris and New York bars, he has over 25 years' experience with international commercial arbitrations, investment arbitrations and other public international law disputes, as well as litigation before domestic and regional courts, such as the Cour Commune de Justice et d’Arbitrage and the Court of Justice of the European Union. Mr. Ostrove routinely acts as lead advocate in arbitrations on behalf of Sovereign States, international organizations, commercial entities, and individuals. He has broad experience in corruption investigations on behalf of multinational corporations and state authorities. Michael sits as an arbitrator, and he is an adjunct professor teaching international arbitration in a Masters program at the Université de Paris II. He is a member of the Advisory Committee to the Wayne State University Law School Program for International Legal Studies and of the Executive Committee of the Foundation for International Arbitration Advocacy.  Mr. Ostrove speaks and publishes frequently on international arbitration and investment law, and he is regularly named as a leading practitioner by the specialized press. Mr. Ostrove earned his B.A. from Yale University, magna cum laude, and his J.D. from the University of California at Berkeley, with Order of the Coif honors.





    Contact Sanctions Board

    The World Bank 1818 H Street, N.W., MSN G 5‐503, Washington, D.C. 20433, U.S.A.
    sanctionsboard@worldbank.org
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    Giuliana Dunham Irving

    Executive Secretary

    Ms. Giuliana Dunham Irving is the current Executive Secretary to the World Bank Group Sanctions Board. She has been with the Sanctions Board Secretariat since October 2016. Ms. Dunham Irving joined the World Bank Group in 2006 as an Institutional Integrity Officer in the Institutional Integrity Department (now the Integrity Vice Presidency). From 2008 to 2012, she held the position of Senior Counsel in Legal Department’s Institutional Administration Unit. From 2012 to 2014, she served as Senior Counsel and Special Assistant to the General Counsel and Senior Vice President of the World Bank Group. From 2014 to September 2016, she held the position of Senior Counsel for Sanctions Policy in the Legal Operations Policy Unit. Ms. Dunham Irving received her Juris Doctor from New York University School of Law in 1992, and completed her undergraduate studies in economics at Columbia College of Columbia University in New York and Universita’ Commerciale Luigi Bocconi in Milan. Ms. Dunham Irving began her legal career as a litigation associate with the firm Debevoise & Plimpton in New York. Prior to joining the World Bank Group, she served as a Trial Attorney in the Fraud Section of the United States Department of Justice and as an Assistant United States Attorney in Washington, D.C.

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    Ryan Velandria McCarthy

    Senior Counsel

    Ryan is Senior Counsel at the Sanctions Board Secretariat, which he joined in April 2013. From 2019-2020, Ryan held the position of Senior Counsel with the World Bank Legal Department’s Institutional Administration Unit (on secondment), where he represented the institution in various litigation matters and served as the primary legal adviser on sanctions policy. Prior to joining the Secretariat, Ryan served as a law clerk on the U.S. District Court for the District of Columbia and worked for several years as a corporate litigator at the law firm, Boies, Schiller & Flexner LLP in New York City. Before working at Boies, Ryan was a Counsellor at the World Bank’s Office of the Special Representative to the U.N. Ryan received his law degree, cum laude, from Harvard Law School, where he was a Chayes International Public Service Fellow. Ryan received his Master’s degree in Comparative Social Policy from Oxford University and he received his undergraduate degree, with honors and Phi Beta Kappa, from the University of Virginia, where he was awarded the Distinguished Student Award. Ryan is a member of the Bar of the State of New York.

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    Eugenia A. Pyntikova

    Counsel

    Eugenia, a dual U.S. and Russian national, joined the Sanctions Board Secretariat in October 2012. Eugenia earned her law degree from Georgetown University Law Center where she served as Notes Editor of the Georgetown Immigration Law Journal and graduated with additional distinctions as a Global Law Scholar and the Law Center's Pro Bono Pledge Honoree. Concurrently with her JD curriculum, Eugenia earned a Master's degree in Public Health from Johns Hopkins University, summa cum laude, where she focused on vaccine policy and humanitarian emergencies. Prior to law school, Eugenia worked for a global bio surveillance project at Georgetown University, where she managed a team of regional analysts monitoring diverse health emergencies. She received her Master of Science degree in Science Policy from Georgetown University and an undergraduate degree from West Virginia University, both summa cum laude. Eugenia is a member of the Bar of the State of Virginia.

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    Anna Lorem Reyes Ramos

    Counsel

    Anna, a Philippine national, joined the Sanctions Board Secretariat in August 2015. Prior to joining the Secretariat, she was a Dispute Settlement Lawyer at the World Trade Organization Appellate Body Secretariat and had been a law clerk for the incumbent Chief Justice of the Supreme Court of the Philippines. Anna also previously worked in litigation in a law firm in Manila. Anna received her Juris Doctor and Bachelor of Science in Economics from the University of the Philippines, and is a member of the Philippine Bar. She obtained her Master of Laws (LL.M.) in Public International Law from Queen Mary, University of London.

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    Felipe Rocha dos Santos

    Counsel

    Felipe, a Brazilian national, joined the Sanctions Board Secretariat in January 2018. Prior to joining the Secretariat, he worked at the law firm Hughes Hubbard & Reed in Washington, D.C. and Paris, where his practice focused on anti-corruption matters and complex, cross-border compliance investigations. Felipe also served as Chief of Division in the Consumer Protection Bureau of Brazil’s Ministry of Justice. He holds a Bachelor of Laws degree, with highest honors, from Universidade Federal do Rio Grande do Sul (UFRGS) in Brazil, and a Master of Laws degree from Harvard Law School. Felipe is a member of the Brazilian Bar and the Bar of the State of New York.     

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    Amanda Schneider

    Legal Assistant

    Amanda, a dual U.S. and Brazilian national, joined the Sanctions Board Secretariat in August 2015. Prior to joining the Secretariat, Amanda has worked across multiple regions in operations and procurement, the Brazil Country Office, Global Practices, and Country Management Units (CMU). Amanda received Advanced Paralegal, Paralegal, and Advanced Legal Research and Writing Certificates from George Mason University.





    Contact Sanctions Board

    The World Bank 1818 H Street, N.W., MSN G 5‐503, Washington, D.C. 20433, U.S.A.
    sanctionsboard@worldbank.org