Yvonne Kozlovsky Golan, Ph.D. (2003), University of Haifa, is Senior Lecturer and founding chair of the Interdisciplinary Program for Culture and Film Studies at that university. Her research focuses on history, cinema and media, especially relating to Israel studies, Holocaust and genocide.

"Yvonne Kozlovsky Golan’s book, Site of Amnesia, enriches our understanding, expands the possibilities for new research, and provides insight into how this unique aspect of the war was addressed and commemorated in film and television over the years."- Haim Saadoun, The Open University of Israel, in Antisemitism Studies 6.1 (2022)

• Preface and AcknowledgementsIntroduction1 Origins and Description of Multilateral Development Banks’ Sanctions RegimesIntroduction1 Origins of Multilateral Development Banks’ Sanctions RegimeA Federal Acquisition Regulation (far)(i) Causes for Debarment(ii) Suspension(iii) Debarment Procedures (iv) Judicial Review and Due Process RightsB Evolution of the World Bank Group’s Sanctions System (i) First Sanctions Regime(ii) The Thornburgh Report(iii) Expansion of Sanctions Regime beyond Procurement and Launch of the Voluntary Disclosure Programme (iv) Early Harmonisation Efforts with Other mdbs 2 Description of Multilateral Development Banks’ Sanctions Regimes A World Bank Group’s Sanctions Regime (i) Two-Step Decision-Making Process (ii) Range of Possible Sanctions (iii) Settlements B Inter-American Development Bank’s Sanctions Regime (i) Early Developments and the Thornburgh Report (ii) Two-Step Decision-Making Process (iii)Range of Possible Sanctions (iv) Settlements C European Bank for Reconstruction and Development’s Sanctions Regime (i) Early Developments (ii) Two-Step Decision-Making Process (iii) Range of Possible Sanctions (iv) Settlements D African Development Bank’s Sanctions Regime (i) Early Developments (ii) Two-Step Decision-Making Process (iii)Range of Possible Sanctions (iv) Settlements E Asian Development Bank’s Sanctions Regime (i) Early Developments (ii) Two-Step Decision-Making Process (iii) Range of Possible Sanctions 3 Comparison of Multilateral Development Banks’ Sanctions Regimes and the Cross-Debarment RegimeA Comparison of Multilateral Development Banks’ Sanctions RegimesB Cross-Debarment RegimeConclusion2 Judicial Review StandardsIntroduction1 Judicial Review Standards in the ukA Bases for Judicial Review B Required Procedures(i) Notice(ii) Right to Make Representations: Written or Oral Proceedings?(iii) Right to Call and Cross-Examine Witnesses(iv) Right to Legal Representation(v) Failure to give Reasons for the Final Decision2 Judicial Review Standards in the USA Bases for Judicial Review B Required ProceduresConclusion3 Accountability of International OrganisationsIntroduction1 Basis of International Organisations’ Immunities2 Case LawA US CourtsB UK CourtsC Italian Courts D French Courts E Belgian Courts F Human Rights Dimension and the echr Conclusion 4 What Legal Principles Should Form the basis of mdbs’ Sanctions Regimes? Introduction 1 Customary Law and General Principles 2 Global Administrative Law 3 Article 6(1) of the European Convention on Human Rights A Civil Rights B Hearing C Independent and Impartial Tribunal 4 Public Judgment/Reasoning of Judicial Decisions (i) Fair Trial 5 Jurisprudence of Multilateral Development Banks’ Administrative Tribunals A Discovery Rights B Oral Hearings and Witnesses C Publication of Decisions D Composition of Administrative Tribunals (i) wbat (ii) UN Appeals Tribunal (iii) imf Administrative Tribunal Conclusion 5 Due Process Standards in Multilateral Development Banks’ Sanctions Regimes Introduction 1 Discovery Rights A Permissive Approach and Production of Documents B Experts’ Reports and Assessment of Evidence C Witnesses and Oral Hearings 2 Publication of Decisions 3 Referral to National Authorities 4 Composition of Sanctions Boards A Sanctions Board Members’ Independence and ImpartialityB Appointment of Sanctions Board Members5 Range of Sanctions and their Proportionality to the Wrongdoing 6 Baseline Sanction 7 Restitution 8 Settlements Conclusion 6 Treatment of Corporate Groups under Multilateral Development Banks’ Sanctions Regimes Introductionv 1 Overview of the Harmonized Principles on Treatment of Corporate Groups 2 Liability of a Company for its Employees’ Wrongdoings A US Law B UK Law C Application of the Foregoing Principles to mdbs’ Sanctions Procedures 3 Liability of a Parent for its Subsidiaries’ Wrongdoings A US Law (i) General Approach (ii) Criminal Liability, Including fcpa (iii) Proposals for Reforms of the US System B UK Law (i) General Approach (ii) Criminal Liability, Including UK Bribery Act C Application of the Foregoing Principles to mdbs’ Sanctions Procedures 4 Liability of a Subsidiary for its Parent’s Wrongdoings A US and EU Sanctions Regimes B Application of the Foregoing Principles to mdbs’ Sanctions Procedures 5 Successor Liability A US Law B UK Law C Application of the Foregoing Principles to mdbs’ Sanctions Procedures Conclusion 7 Conclusion and Way Forward Bibliography Index

Yvonne Kozlovsky Golan, Ph.D. (2003), University of Haifa, is Senior Lecturer and founding chair of the Interdisciplinary Program for Culture and Film Studies at that university. Her research focuses on history, cinema and media, especially relating to Israel studies, Holocaust and genocide.

"Yvonne Kozlovsky Golan’s book, Site of Amnesia, enriches our understanding, expands the possibilities for new research, and provides insight into how this unique aspect of the war was addressed and commemorated in film and television over the years."- Haim Saadoun, The Open University of Israel, in Antisemitism Studies 6.1 (2022)

• Preface and AcknowledgementsIntroduction1 Origins and Description of Multilateral Development Banks’ Sanctions RegimesIntroduction1 Origins of Multilateral Development Banks’ Sanctions RegimeA Federal Acquisition Regulation (far)(i) Causes for Debarment(ii) Suspension(iii) Debarment Procedures (iv) Judicial Review and Due Process RightsB Evolution of the World Bank Group’s Sanctions System (i) First Sanctions Regime(ii) The Thornburgh Report(iii) Expansion of Sanctions Regime beyond Procurement and Launch of the Voluntary Disclosure Programme (iv) Early Harmonisation Efforts with Other mdbs 2 Description of Multilateral Development Banks’ Sanctions Regimes A World Bank Group’s Sanctions Regime (i) Two-Step Decision-Making Process (ii) Range of Possible Sanctions (iii) Settlements B Inter-American Development Bank’s Sanctions Regime (i) Early Developments and the Thornburgh Report (ii) Two-Step Decision-Making Process (iii)Range of Possible Sanctions (iv) Settlements C European Bank for Reconstruction and Development’s Sanctions Regime (i) Early Developments (ii) Two-Step Decision-Making Process (iii) Range of Possible Sanctions (iv) Settlements D African Development Bank’s Sanctions Regime (i) Early Developments (ii) Two-Step Decision-Making Process (iii)Range of Possible Sanctions (iv) Settlements E Asian Development Bank’s Sanctions Regime (i) Early Developments (ii) Two-Step Decision-Making Process (iii) Range of Possible Sanctions 3 Comparison of Multilateral Development Banks’ Sanctions Regimes and the Cross-Debarment RegimeA Comparison of Multilateral Development Banks’ Sanctions RegimesB Cross-Debarment RegimeConclusion2 Judicial Review StandardsIntroduction1 Judicial Review Standards in the ukA Bases for Judicial Review B Required Procedures(i) Notice(ii) Right to Make Representations: Written or Oral Proceedings?(iii) Right to Call and Cross-Examine Witnesses(iv) Right to Legal Representation(v) Failure to give Reasons for the Final Decision2 Judicial Review Standards in the USA Bases for Judicial Review B Required ProceduresConclusion3 Accountability of International OrganisationsIntroduction1 Basis of International Organisations’ Immunities2 Case LawA US CourtsB UK CourtsC Italian Courts D French Courts E Belgian Courts F Human Rights Dimension and the echr Conclusion 4 What Legal Principles Should Form the basis of mdbs’ Sanctions Regimes? Introduction 1 Customary Law and General Principles 2 Global Administrative Law 3 Article 6(1) of the European Convention on Human Rights A Civil Rights B Hearing C Independent and Impartial Tribunal 4 Public Judgment/Reasoning of Judicial Decisions (i) Fair Trial 5 Jurisprudence of Multilateral Development Banks’ Administrative Tribunals A Discovery Rights B Oral Hearings and Witnesses C Publication of Decisions D Composition of Administrative Tribunals (i) wbat (ii) UN Appeals Tribunal (iii) imf Administrative Tribunal Conclusion 5 Due Process Standards in Multilateral Development Banks’ Sanctions Regimes Introduction 1 Discovery Rights A Permissive Approach and Production of Documents B Experts’ Reports and Assessment of Evidence C Witnesses and Oral Hearings 2 Publication of Decisions 3 Referral to National Authorities 4 Composition of Sanctions Boards A Sanctions Board Members’ Independence and ImpartialityB Appointment of Sanctions Board Members5 Range of Sanctions and their Proportionality to the Wrongdoing 6 Baseline Sanction 7 Restitution 8 Settlements Conclusion 6 Treatment of Corporate Groups under Multilateral Development Banks’ Sanctions Regimes Introductionv 1 Overview of the Harmonized Principles on Treatment of Corporate Groups 2 Liability of a Company for its Employees’ Wrongdoings A US Law B UK Law C Application of the Foregoing Principles to mdbs’ Sanctions Procedures 3 Liability of a Parent for its Subsidiaries’ Wrongdoings A US Law (i) General Approach (ii) Criminal Liability, Including fcpa (iii) Proposals for Reforms of the US System B UK Law (i) General Approach (ii) Criminal Liability, Including UK Bribery Act C Application of the Foregoing Principles to mdbs’ Sanctions Procedures 4 Liability of a Subsidiary for its Parent’s Wrongdoings A US and EU Sanctions Regimes B Application of the Foregoing Principles to mdbs’ Sanctions Procedures 5 Successor Liability A US Law B UK Law C Application of the Foregoing Principles to mdbs’ Sanctions Procedures Conclusion 7 Conclusion and Way Forward Bibliography Index

Yvonne Kozlovsky Golan, Ph.D. (2003), University of Haifa, is Senior Lecturer and founding chair of the Interdisciplinary Program for Culture and Film Studies at that university. Her research focuses on history, cinema and media, especially relating to Israel studies, Holocaust and genocide.

"Yvonne Kozlovsky Golan’s book, Site of Amnesia, enriches our understanding, expands the possibilities for new research, and provides insight into how this unique aspect of the war was addressed and commemorated in film and television over the years."- Haim Saadoun, The Open University of Israel, in Antisemitism Studies 6.1 (2022)

• Preface and AcknowledgementsIntroduction1 Origins and Description of Multilateral Development Banks’ Sanctions RegimesIntroduction1 Origins of Multilateral Development Banks’ Sanctions RegimeA Federal Acquisition Regulation (far)(i) Causes for Debarment(ii) Suspension(iii) Debarment Procedures (iv) Judicial Review and Due Process RightsB Evolution of the World Bank Group’s Sanctions System (i) First Sanctions Regime(ii) The Thornburgh Report(iii) Expansion of Sanctions Regime beyond Procurement and Launch of the Voluntary Disclosure Programme (iv) Early Harmonisation Efforts with Other mdbs 2 Description of Multilateral Development Banks’ Sanctions Regimes A World Bank Group’s Sanctions Regime (i) Two-Step Decision-Making Process (ii) Range of Possible Sanctions (iii) Settlements B Inter-American Development Bank’s Sanctions Regime (i) Early Developments and the Thornburgh Report (ii) Two-Step Decision-Making Process (iii)Range of Possible Sanctions (iv) Settlements C European Bank for Reconstruction and Development’s Sanctions Regime (i) Early Developments (ii) Two-Step Decision-Making Process (iii) Range of Possible Sanctions (iv) Settlements D African Development Bank’s Sanctions Regime (i) Early Developments (ii) Two-Step Decision-Making Process (iii)Range of Possible Sanctions (iv) Settlements E Asian Development Bank’s Sanctions Regime (i) Early Developments (ii) Two-Step Decision-Making Process (iii) Range of Possible Sanctions 3 Comparison of Multilateral Development Banks’ Sanctions Regimes and the Cross-Debarment RegimeA Comparison of Multilateral Development Banks’ Sanctions RegimesB Cross-Debarment RegimeConclusion2 Judicial Review StandardsIntroduction1 Judicial Review Standards in the ukA Bases for Judicial Review B Required Procedures(i) Notice(ii) Right to Make Representations: Written or Oral Proceedings?(iii) Right to Call and Cross-Examine Witnesses(iv) Right to Legal Representation(v) Failure to give Reasons for the Final Decision2 Judicial Review Standards in the USA Bases for Judicial Review B Required ProceduresConclusion3 Accountability of International OrganisationsIntroduction1 Basis of International Organisations’ Immunities2 Case LawA US CourtsB UK CourtsC Italian Courts D French Courts E Belgian Courts F Human Rights Dimension and the echr Conclusion 4 What Legal Principles Should Form the basis of mdbs’ Sanctions Regimes? Introduction 1 Customary Law and General Principles 2 Global Administrative Law 3 Article 6(1) of the European Convention on Human Rights A Civil Rights B Hearing C Independent and Impartial Tribunal 4 Public Judgment/Reasoning of Judicial Decisions (i) Fair Trial 5 Jurisprudence of Multilateral Development Banks’ Administrative Tribunals A Discovery Rights B Oral Hearings and Witnesses C Publication of Decisions D Composition of Administrative Tribunals (i) wbat (ii) UN Appeals Tribunal (iii) imf Administrative Tribunal Conclusion 5 Due Process Standards in Multilateral Development Banks’ Sanctions Regimes Introduction 1 Discovery Rights A Permissive Approach and Production of Documents B Experts’ Reports and Assessment of Evidence C Witnesses and Oral Hearings 2 Publication of Decisions 3 Referral to National Authorities 4 Composition of Sanctions Boards A Sanctions Board Members’ Independence and ImpartialityB Appointment of Sanctions Board Members5 Range of Sanctions and their Proportionality to the Wrongdoing 6 Baseline Sanction 7 Restitution 8 Settlements Conclusion 6 Treatment of Corporate Groups under Multilateral Development Banks’ Sanctions Regimes Introductionv 1 Overview of the Harmonized Principles on Treatment of Corporate Groups 2 Liability of a Company for its Employees’ Wrongdoings A US Law B UK Law C Application of the Foregoing Principles to mdbs’ Sanctions Procedures 3 Liability of a Parent for its Subsidiaries’ Wrongdoings A US Law (i) General Approach (ii) Criminal Liability, Including fcpa (iii) Proposals for Reforms of the US System B UK Law (i) General Approach (ii) Criminal Liability, Including UK Bribery Act C Application of the Foregoing Principles to mdbs’ Sanctions Procedures 4 Liability of a Subsidiary for its Parent’s Wrongdoings A US and EU Sanctions Regimes B Application of the Foregoing Principles to mdbs’ Sanctions Procedures 5 Successor Liability A US Law B UK Law C Application of the Foregoing Principles to mdbs’ Sanctions Procedures Conclusion 7 Conclusion and Way Forward Bibliography Index