LCIL Talk: 'Accountability Mechanisms in International Organizations: The World Bank Sanctions System and the Fight against Corruption in International Development' - Felipe Rocha dos Santos

In-person event only.

Corruption drains public resources, distorts markets, and erodes trust in institutions—but how do international organizations tackle this pervasive challenge? International financial institutions like the World Bank invest billions in development projects each year, but without strong safeguards, these funds can be lost to fraud, bribery, and other forms of misconduct. Ensuring accountability in this context requires more than just financial oversight—it demands a robust legal framework to investigate misconduct and impose sanctions on wrongdoers. To that end, international financial institutions often establish internal mechanisms to uphold integrity standards and deter misuse of funds. 
 
The World Bank Group (WBG) Sanctions System is a unique and evolving legal framework that holds companies and individuals accountable for fraud and corruption in development projects worldwide—operating outside national courts but with profound global consequences. This session will offer an in-depth look at this system, exploring key legal questions: What is the basis of the WBG’s jurisdiction? What due process standards apply within an international organization? How do the administrative decisions of an international financial institution interact with national and international legal frameworks and enforcement authorities?
 
Felipe Rocha dos Santos is a Brazilian attorney specializing in international development, regulatory enforcement, and integrity matters. He serves as Senior Counsel to the WBG Sanctions Board, an international administrative tribunal that adjudicates sanctions cases involving fraud and corruption in WBG operations. He also contributes to the Stolen Asset Recovery Initiative (StAR), a joint effort by the WBG and the United Nations to combat transnational financial crime. In this capacity, he has led key publications, including a report on asset recovery mechanisms for the G20 Anti-Corruption Working Group. Before joining the WBG, Felipe worked in private practice in Washington, D.C., and Paris, conducting high-profile anti-corruption investigations and compliance audits in Latin America and Africa. He also served in Brazil’s Ministry of Justice, advising on consumer protection policies and regulation and representing Brazil in international negotiations. Felipe holds an LL.B. with highest honors from Universidade Federal do Rio Grande do Sul (UFRGS) and an LL.M. from Harvard Law School. He is licensed to practice law in Brazil, New York, and the District of Columbia, and is a Certified Fraud Examiner (CFE). 
 

Chair: Dr Fernando Lusa Bordin, Centre Fellow