Brigida Benitez

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The Department of Justice (DOJ) “KleptoCapture” Task Force (the “Task Force”), launched shortly after Russia’s invasion of Ukraine earlier this year, is characterized by DOJ as a key part of the current Administration’s broader anti-corruption initiative. The role of the Task Force is to support the enforcement of sanctions and export control restrictions imposed against Russia in response to the conflict. Earlier this month, Andrew Adams, the Task Force’s director, discussed its work to date, expected future developments, and implications for private sector companies.[1] Highlights of his remarks are summarized below, along with our comments on key points addressed.…

Continue Reading Department of Justice KleptoCapture Task Force – Director Andrew Adams Shares Observations on Current Efforts and Expected Developments

The World Bank Group (the Bank) issued its fourth joint Sanctions System Annual Report on October 18, covering the Bank’s fiscal year from July 1, 2020 through June 30, 2021. The report includes updates by the Integrity Vice Presidency (INT), the Office of Suspension and Debarment (OSD), and the Sanctions Board.

Notably, the number of…

In a recent roundtable as part of the World Bank Office of Suspension and Debarment’s Fifth International Debarment Colloquium, panelist Joseph Mauro (an Integrity Compliance Specialist with the Bank’s Integrity Vice Presidency (INT)) discussed efforts to move from a “stick” to a “carrot” approach with respect to corporate compliance programs.

Under the Bank’s current system, while implementation of a compliance program is a remedial measure for which mitigating credit may apply, individuals within the Integrity Compliance Office were rarely involved in reviewing a compliance program to any significant extent until after a company has already been sanctioned. Under this process, a company’s compliance program was typically reviewed in-depth only as a condition for release from sanction.

Mr. Mauro described a new initiative, which has been ongoing for the past 6-12 months, under which the Bank hopes to incentivize companies to adopt compliance programs prior to allegations of misconduct. Under the new system, the Integrity Compliance Office will work with INT investigators to perform a thorough compliance program analysis before a company is sanctioned to determine whether mitigation is warranted.…

Continue Reading World Bank Purports to Move From “Stick” to “Carrot” Approach on Compliance

On July 3, the US Department of Justice (DOJ) and Securities and Exchange Commission (SEC) issued the second edition of the Resource Guide to the US Foreign Corrupt Practices Act (the 2020 Guide), the first full-scope overhaul of the Resource Guide since its issuance in 2012.

As with the original edition, the 2020 Guide will…

The World Bank Group (the Bank) published a joint Sanctions System Annual Report for fiscal year 2019 on October 10. This report, which reflects on the Sanctions System’s growth since its implementation twenty years ago, provides an overview of activities undertaken by the Bank’s Integrity Vice Presidency (INT), Office of Suspension and Debarment (OSD), and…

Steptoe’s Brigida Benitez and John London authored an article in The Maryland Journal of International Law titled “Has the International Olympic Committee Risen Above Corruption?” The article reviews the International Olympic Committee’s rules and procedures to assess their adequacy in addressing potential corruption.

More information is available here.