Feb. 4, 2014 – Meng Lu
Over the summer I worked at the Special Litigation Unit of the Integrity Vice Presidency (INT) within the World Bank Group in Washington, D.C. The World Bank Sanction system is a two tier adjudicative system akin to an administrative court. It consisted of a trial court-like first level sanction officer and a second level appellate board. I worked for the team that acted as the prosecutors in the system. The lawyers, who hailed from different countries, brought cases relating to fraud, corruption, and certain antitrust issues in World Bank-funded Projects.
During my time with the Special Litigation Unit I worked on two Statements of Evidence and Accusation, which are the equivalent of complaints in domestic American courts. Specifically, I worked on two cases in Africa, both involving companies that allegedly engaged in corrupt and/or fraudulent practices. One of the cases was sent to the Office of Evaluation and Suspension, which had, among others, the ability to debar a company from taking out World Bank loans. On a conceptual level, I enjoyed the process of learning about the novel enforcement framework for international and domestic corruption. The team was full of inspirational individuals who have a real passion for the fight against corruption. Researching applicable rules, compiling evidence, and writing the Statement of Evidence and Accusation was challenging, interesting, and substantial.
In addition to the day-to-day legal work, the World Bank is also going through a change initiative under the New President, Jim Yong Kim, which sparked interesting discussions within the Bank. Lawyers perform specific and highly specialized advisory and policy functions within the World Bank and INT is a fascinating place to work, especially for those interested in development and corruption. There are very few anti-corruption enforcement frameworks in the world right now. The World Bank sanction system, alongside FCPA and the UK Bribery Act, offers the best international efforts to combat corruption. The World Bank provides a fantastic, if not sometime slightly bureaucratic experience. Nevertheless, it was great to see the inner workings of the great development machinery.