Workshop 6: Enhancing Investigations: Lessons from MDB Sanctions Appellate Bodies

Workshop 6 highlights practical lessons drawn from the appellate levels of sanctions mechanisms at several MDBs, which are the final stop for many complex fraud and corruption cases. Staff of professional secretariats will share insights regarding the common rules, challenges, and best practices for adversarial proceedings before such decisionmakers.
Alan
Alan Bacarese (WB)
Alan joined the World Bank Group’s Integrity Vice Presidency (INT) as Director of Investigations, Strategy, and Operations in February 2021.
In this role, Alan oversees INT’s investigations of alleged fraud, corruption, and other sanctionable practices involving projects and activities financed by the World Bank Group, its corporate vendors, and World Bank Group staff, as well as efforts to litigate substantiated investigations within the World Bank Group’s Sanctions System. He also manages INT’s Prevention, Risk, and Knowledge Management function, to promote best practices in the prevention of fraud and corruption in World Bank Group–supported projects. In addition, Alan provides support to INT’s Vice President in setting the strategic priorities for the unit’s overall anticorruption efforts.
Alan has over 30 years experience in investigating and prosecuting matters of international fraud and corruption. Before joining INT, he was the Director of Integrity and Anti-Corruption for the African Development Bank, where he led the Bank’s anticorruption investigation function and its policies on anticorruption and integrity measures, as well as the Bank’s business integrity due diligence function. His past roles include serving as a UK Senior Crown Prosecutor, the first Head of Legal and Case Consultancy at the Basel Institute’s International Centre for Asset Recovery and an External Member of the Inter-American Development Bank’s Sanctions Committee. Alan is a UK national and holds an LLB (Hons.) in law and is qualified as a UK Barrister and an Advocate of the Higher Courts of England and Wales.  He is the author of many published articles, technical papers and is a co-author to the UK’s leading UK legal text on Corruption and Misconduct in Public Office (published by OUP – 4th Ed. – https://academic.oup.com/book/58180).
Jodi
Jodi T. Glasow (WB)
Ms. Jodi T. Glasow, a Canadian national, serves as Executive Secretary to the World Bank Group Sanctions Board. Since joining the World Bank Group in 2002, she has held several key positions, including Chief Counsel of the internal investigations unit within the Department of Ethics and Business Conduct; Executive Secretary of Peer Review Services – a unit of the Bank’s Internal Justice System dedicated to reviewing employee contractual disputes; and Executive Secretary (Acting) as well as Senior Counsel to the Appeals Committee. In each of these roles, Ms. Glasow has represented the World Bank at numerous international forums, committees, and organizations. She is recognized for pioneering innovative reforms and devising unique solutions to complex institutional challenges, leading to transformative and lasting improvements in the Bank’s processes and procedures. Prior to her tenure at the World Bank, Ms. Glasow practiced law in Washington, D.C., focusing on labor and employment litigation. She also worked for many years at the Canadian Embassy in Washington, D.C. Ms. Glasow is admitted to the Bars of Virginia, Pennsylvania, and the District of Columbia. She holds a Juris Doctor degree from the Washington College of Law at American University and a Bachelor of Arts in Economics and Political Science from McGill University in Montreal, Canada.
Jhon
Jhon Carmona (IDB)
Jhon Carmona has 17 years of experience advising international organizations and government entities on international administrative law, dispute resolution, integrity, and the law of international organizations. He has held professional posts in Switzerland, the United States, Korea, and Peru.
Mr. Carmona earned his first law degree from the Universidad de San Marcos in Lima and holds a Master of Laws (LL.M.) from Harvard Law School. He has also served as a postdoctoral fellow at Yale Law School and as a visiting scholar at Columbia University.
He is licensed to practice law in both New York and Peru, and is admitted to the Bar of the Supreme Court of the United States. Mr. Carmona is fluent in English, Spanish, Italian, and French.
Po-Sian
Po-Siann Goh (EBRD)
Po-Siann Goh is Principal Counsel at the European Bank for Reconstruction and Development.  Following her appointment to the Secretariat of EBRD’s Enforcement Committee, Po-Siann assisted the Committee in the first appeal under the 2017 version of the Enforcement Policy and Procedures.  Po-Siann is also a member of the OGC Corporate Recovery team at EBRD’s Office of General Counsel.
Prior to joining EBRD, Po-Siann specialised in dispute resolution in a major law firm in London. 

CII General Principles for Core Investigative Activities

Six volumes of General Principles for conducting core investigative activities that greatly expand on the principles within the CII’s Uniform Principles and Guidelines for Investigations. Endorsed at the 21st CII, these Principles provide more in-depth, principles-based, uniform guidance to investigators and Investigative Offices conducting these six core activities: Intake and Evaluation, Scoping and Planning, collection of Physical and Documentary Evidence, collection of Testimonial Evidence, collection of Digital Evidence and Evidence Analysis and Reporting of Findings.

As supplements to the CII’s Uniform Principles and Guidelines, each paper sets out non-binding principles establishing uniform standards to guide investigators and Investigative Offices undertaking these activities. They are purposely not prescriptive in technical details nor implementing practices. These Principles will also form the basis for a future CII Investigator Credential and CII Investigator training pathways.