Treasury Targets Vessel Shipping Iranian Commodities for Houthis and Qods Force

WASHINGTON — Today, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) is taking action against Marshall Islands-registered shipping company Vishnu Inc., whose vessel, the LADY SOFIA, is involved in illicit shipments to the People’s Republic of China (PRC) in support of Iran’s Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF) and Houthi financial facilitator Sa’id al-Jamal, who is sanctioned under U.S. counterterrorism authorities. 

“We remain committed to disrupting the IRGC-QF and the Houthis’ attempts to evade U.S. sanctions and fund additional terrorist attacks,” said Under Secretary of the Treasury for Terrorism and Financial Intelligence Brian E. Nelson. “The United States will continue to target the key funding streams that threaten civilians and peaceful international trade.”

Today’s action is being taken pursuant to the counterterrorism authority in Executive Order (E.O.) 13224, as amended. OFAC designated Sa’id al-Jamal pursuant to E.O. 13224, as amended, on June 10, 2021 for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, the IRGC-QF. The IRGC-QF was designated pursuant to E.O. 13224 on October 25, 2007 for providing support to multiple terrorist groups.

IRGC-QF FINANCIAL SUPPORT TO THE HOUTHIS 

The Vishnu Inc. owned and managed LADY SOFIA (IMO: 9212759) engaged in a ship-to-ship transfer with the recently sanctioned vessel MEHLE (IMO: 9191711) on January 31, 2024, which deceptively obscured its transfer of commodities to the LADY SOFIA through “spoofing”—an automatic identification system (AIS) manipulation that masks the vessel’s true location. Disguised as a fictitious vessel called the “AMOR,” and incorrectly broadcasting its location as the South China Sea, the MEHLE offloaded its illicit cargo to the LADY SOFIA near Singapore. The LADY SOFIA is currently traveling to the PRC, carrying the Iranian commodities it received from the MEHLE on behalf of Sa’id al-Jamal.

The MEHLE was identified on January 12, 2024, as property in which Cielo Maritime Ltd has an interest.  Cielo Maritime Ltd was concurrently designated pursuant to E.O. 13224, as amended, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Sa’id al-Jamal.

Vishnu Inc. is being designated pursuant to E.O. 13224, as amended, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Sa’id al-Jamal.  The LADY SOFIA is being identified as property in which Vishnu Inc. has an interest.

SANCTIONS IMPLICATIONS

As a result of today’s action, all property and interests in property of the designated person described above that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC. In addition, any entities that are owned, directly or indirectly, individually or in the aggregate, 50 percent or more by one or more blocked persons are also blocked. Unless authorized by a general or specific license issued by OFAC, or exempt, OFAC’s regulations generally prohibit all transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of designated or otherwise blocked persons. 

In addition, financial institutions and other persons that engage in certain transactions or activities with the sanctioned entity and its blocked property may expose themselves to sanctions or be subject to an enforcement action. The prohibitions include the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any designated person, or the receipt of any contribution or provision of funds, goods, or services from any such person. 

The power and integrity of OFAC sanctions derive not only from OFAC’s ability to designate and add persons to the SDN List, but also from its willingness to remove persons from the SDN List consistent with the law. The ultimate goal of sanctions is not to punish, but to bring about a positive change in behavior. For information concerning the process for seeking removal from an OFAC list, including the SDN List, please refer to OFAC’s Frequently Asked Question 897 here. For detailed information on the process to submit a request for removal from an OFAC sanctions list, please click here.

Click here for more information on the individuals and entities designated today.

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READOUT: Under Secretary for Terrorism and Financial Intelligence Brian Nelson’s Travel to Japan

TOKYO – On March 13 and 14, Under Secretary of the Treasury for Terrorism and Financial Intelligence Brian E. Nelson held meetings in Tokyo, Japan to continue close coordination between the two G7 allies on pressing national security issues, including countering Russian attempts to evade multilateral sanctions and export controls particularly through third countries; protecting maritime shipping from illegal, dangerous, and destabilizing Houthi attacks; and on cyber threats and ransomware.

While in Tokyo, Under Secretary Nelson met with senior government officials including Ministry of Finance Vice Minister for International Affairs Masato Kanda, Ministry of Foreign Affairs Senior Deputy Minister for Foreign Affairs Keiichi Ono, Bank of Japan Deputy Governor Ryozo Himino, and Financial Services Agency Vice Minister for International Affairs Shigeru Ariizumi. The United States has worked closely with Japan both bilaterally and via multilateral groups, including the Financial Action Task Force and the G7, to prevent terrorists, money launderers, and other illicit actors from accessing the international financial system, and to counter sanctions evasion from actors like Russia, Iran, and North Korea. The Under Secretary also met with private sector representatives from banks and multinational companies to discuss geopolitical issues and ways that the private sector and governments can work together to detect and prevent illicit finance.

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READOUT: Assistant Secretary for International Finance Brent Neiman’s Travel to Argentina

BUENOS AIRES – From March 13-15, Assistant Secretary for International Finance Brent Neiman visited Buenos Aires and met with senior members of President Milei’s administration, including Minister of Economy Luis Caputo, Secretary of Finance Pablo Quirno, and Central Bank of the Argentine Republic President Santiago Bausili and Vice President Vladimir Werning. Assistant Secretary Neiman also met with private sector and labor representatives. 

Assistant Secretary Neiman expressed Treasury’s support for the Argentinian people and emphasized our longstanding economic ties. He welcomed efforts by the authorities to restore fiscal stability and to effect disinflation, while protecting the most vulnerable. He also welcomed ongoing engagement with international financial institutions. 

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Treasury Announces Cyber Security Cooperation Memorandum of Understanding with Finland

WASHINGTON – Today, the U.S. Department of the Treasury announced that it has signed a cyber security cooperation memorandum of understanding with Finland. The Memorandum of Understanding (MoU) will facilitate exchange of information on cybersecurity between the Finnish Ministry of Finance and the Treasury Department.

“Effective information sharing is critical to building operational resilience. This partnership will help Treasury protect the financial sector from emerging threats while reinforcing our ability to coordinate incident response with our allies abroad,” said Todd Conklin, Deputy Assistant Secretary for Cybersecurity and Critical Infrastructure Protection.

The representatives of the Finnish Ministry of Finance and the US Treasury Department signed the MoU on March 13, 2024. The document is not legally binding.

The MoU establishes practices for sharing information about cybersecurity threats and incidents, cyber threat actors and various best practices, and is guided by the principles of voluntariness, timeliness, anonymity, and confidentiality. It also encourages parties to carry out visits, exchange views, and conduct exercises and training.

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Biden-Harris Administration Announces New Funding to Expand High Speed Internet in New Mexico Tribal Communities as Part of President Biden’s Investing in America Agenda

American Rescue Plan funding, administered by the Treasury Department, will fund improved broadband internet access in Tribal communities  

ALBUQUERQUE, NM – Today, at the Indian Pueblo Cultural Center in Albuquerque, New Mexico, the Biden-Harris Administration announced the approval of $10 million for multi-purpose facilities in Tribal communities under the U.S. Department of the Treasury’s Capital Projects Fund (CPF), part of President Biden’s Investing in America agenda.  

Today’s announcement will fund New Mexico’s Tribal Library Broadband-Ready Facility Improvement Program, which will construct a new childcare center and improve and expand six libraries and family resource centers within Tribal communities to help ensure Native Americans have access to educational programming, health and career services, and social supports in their communities. Upon completion of the projects, all facilities will provide broadband internet and computers to directly enable work, education, and health monitoring within their communities, currently among the state’s least served in terms of broadband access. New Mexico estimates that the facilities will serve thousands of Tribal community members annually across seven Pueblos, Tribes, and Indian Nations across the state. 

“Connecting workers and families to job training, education, and health care is key to expanding economic opportunity,” said U.S. Deputy Secretary of the Treasury Wally Adeyemo. “These resources from President Biden’s American Rescue Plan will increase access to high-speed internet for some of the least connected Tribal communities in New Mexico, helping Indian County thrive.” 

“I’m very proud that, through the American Rescue Plan, President Biden signed into law the largest single investment in Indian Country in our history,” said Senior Advisor to President Biden and White House Coordinator for the American Rescue Plan Gene Sperling. “The American Rescue Plan funds deployed by Governor Lujan Grisham to uplift and modernize libraries and childcare centers in the pueblo communities is a tremendous way to use these funds to ensure their children emerge from the pandemic with brighter and stronger futures. I’m honored to join Governor Lujan Grisham, the leaders of these pueblos, and the Albuquerque community to see firsthand how they are building economic and educational opportunity from the bottom up and middle out as President Biden so strongly believes.” 

“Investment in broadband and other critical infrastructure is essential to the overall health and well-being of tribal communities,” said New Mexico Governor Michelle Lujan Grisham. “The funding announced today will improve access to education, workforce development tools, career counseling, telehealth and other services that create opportunities and improve lives. I thank the Biden Administration for their commitment to assisting New Mexico tribes.” 

“The Pueblo of Sandia Tribal Council recognizes that studies have shown the shape of a building (particularly a school building) can have an impact on brain development. Many of today’s schools were built 50-60 years ago. These buildings were not designed for change and are very static and linear in design,” said Sandia Pueblo Governor Felix Chaves. “Twenty-first Century educators are developing new and innovative ways to teach, only to be hindered by obsolete spaces that prevent them from giving students the best learning experiences. Rather than selecting a traditional linear design for the new CDC, the Blossom Circular plan was developed to inspire creativity in children who are developing new ways of thinking about their world and are no longer bound by linear patterns of thought. Thinking has become more multi-dimensional, and building design should reflect this.” 

“Access to reliable, high-speed internet is a necessity to keep up with everyday life. But right now, too many Tribes in New Mexico lack access to this essential service,” said Senator Martin Heinrich. “I’m proud to welcome $10 million from our American Rescue Plan to help Tribes and Pueblos close the digital divide and ensure that every family has the tools needed to thrive in their communities.” 

“This critical investment, made possible by the American Rescue Plan, gets us closer to 100% connectivity by delivering $10 million in funding to support libraries on Tribal lands,” said Senator Ben Ray Luján. “Senator Heinrich and I have long worked to expand federal support for broadband at Tribal libraries. Whether completing homework, conducting research, or operating in the digital economy, these libraries serve as an essential hub for communities around New Mexico. That’s why I’m honored to welcome this funding that will ensure seven libraries and family resource centers in Tribal communities have access to a reliable internet connection.” 

“I am honored to announce $10 million for New Mexico’s Tribal Library Broadband-Ready Facility Improvement Program–a vital step in bridging the digital gap across seven Pueblos, Tribes and Nations in our state,” said Representative Gabe Vasquez (NM-02). “By prioritizing broadband internet and computer access, we’re ensuring Native American communities have the tools they need to access education, health services and career opportunities. I stand committed to supporting the sovereignty and prosperity of Indian Country and ensuring they have equal access to essential resources.” 

The American Rescue Plan’s (ARP) Capital Projects Fund provides $10 billion to states, territories, freely associated states, and Tribal governments to fund critical capital projects that expand economic opportunities and provide internet connectivity in communities with unmet needs. Through high-speed internet, multi-purpose community facilities, and digital technology investments like the one being announced today, CPF funding is both closing the digital divide and bringing workforce, education, and health care services to communities in need. 

Today’s announcement is in addition to the $117 million in CPF funding for broadband infrastructure in New Mexico announced in 2022, which the state estimates will connect over 40,000 homes and businesses to affordable, high-speed internet. To date, the Treasury Department has awarded more than $9.2 billion in CPF funding for broadband, digital technology, and multi-purpose community center projects in all 50 states and the District of Columbia, which will reach more than 2 million locations with improved internet access. In addition, hundreds of thousands of individuals will be served annually by multi-purpose community facilities and digital technology programs. An additional $78 million in CPF awards have gone to 440 Tribal governments. 

This CPF funding is one example of how the Biden-Harris Administration has made strengthening the self-determination and economic vitality of Tribal Nations and Native people a key priority, including through the implementation of President Biden’s American Rescue Plan (ARP). The ARP included over $30 billion for Tribal governments, including $20 billion from the State and Local Fiscal Recovery Funds (SLFRF) program – the largest single infusion of federal funding into Indian Country in U.S. history. This week, during virtual remarks at the National Center for American Indian Enterprise Development’s (NCAIED) 2024 Reservation Economic Summit (RES), Secretary of the Treasury Janet L. Yellen announced new small business funding for Tribes under the State Small Business Credit Initiative (SSBCI), reauthorized and expanded by the ARP. To date, the Treasury Department has approved $265 million in SSBCI funding for 80 Tribes. 

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Treasury Department Announces New Funding to Support Small Businesses in Six States and Three U.S. Territories as Part of the Biden-Harris Administration’s Investing in America Agenda

WASHINGTON – As part of the Biden-Harris Administration’s Investing in America Agenda, the U.S. Department of the Treasury today announced six new awards to states and two new awards to territories under the State Small Business Credit Initiative (SSBCI) Technical Assistance Grant Program, totaling more than $27 million. These awards will be used to provide legal, accounting, and financial advisory services to eligible small businesses applying for the SSBCI capital program and other government small business programs. In addition, the Department is announcing an award of more than $57 million for American Samoa under the SSBCI Capital Program. 

“The Biden-Harris Administration continues to invest in the historic small business boom by providing small businesses and entrepreneurs the resources they need to succeed,” said Deputy Secretary Wally Adeyemo. “Today’s announcements will help unlock the potential of entrepreneurs in underserved communities across the nation who have not had the support to pursue their business ideas and ambitions.” 

President Biden’s American Rescue Plan reauthorized and expanded SSBCI, which was originally established in 2010 and was highly successful in increasing access to capital for small businesses and entrepreneurs. The new SSBCI builds on this successful model by providing nearly $10 billion to states, the District of Columbia, territories, and Tribal governments to increase access to capital and promote entrepreneurship, especially in traditionally underserved communities. SSBCI funding is expected to catalyze up to $10 of private investment for every $1 of SSBCI capital funding, amplifying the effects of this funding and providing small business owners with the resources they need to sustainably grow and thrive.   

The expanded SSBCI includes funding for technical assistance to help very small businesses – defined as businesses with fewer than 10 employees, including independent contractors and sole proprietors – and underserved small businesses apply for the SSBCI Capital Program and other government small business programs. The Treasury Department’s SSBCI Technical Assistance Grant Program and the newly announced SSBCI Investing in America Small Business Opportunity Program are both designed to complement the SSBCI Capital Program. While access to capital is a key component for small business stability, resiliency, and growth – particularly for historically underserved small businesses – additional technical support will help small businesses secure and maximize that capital. The Technical Assistance Program will provide vital aid to help small businesses become “capital ready” by preparing them to take on loans or investment and steward capital for small business success.        

From today’s awards, here are examples of how Bidenomics is helping expand access to capital and provide legal, accounting, and financial advisory services to small businesses:  

  • West Virginia, approved for $1.5 million in Technical Assistance (TA) grant funding, will work with Partner Community Capital, Inc. (PCAP) to administer its TA program to applicants and participants of the West Virginia Capital Access Program. PCAP, a leading Community Development Financial Institution serving small businesses in West Virginia, will provide financial advisory services, one-on-one consulting, and educational programs. West Virginia anticipates that it will serve 140 small businesses through the four-year program, including up to 10 start-up small businesses a year.  
  • Puerto Rico, approved for $3.8 million in SSBCI TA grant funding, will utilize the Economic Development Bank of Puerto Rico (EDB) to provide legal, accounting, and financial advisory services to companies preparing to apply for support from state and/or federal small business programs and connect companies directly with its SSBCI-supported capital programs. The EDB will conduct data analysis to understand small business TA needs and continually evaluate desired program outcomes and will provide group training sessions, one-on-one counseling, and online education to prepare small businesses to apply for funding. 
  • Kansas, approved for $1.3 million in SSBCI TA grant funding, will work with the Kansas Department of Commerce and NetWork Kansas to identify underserved and very small businesses and match those businesses with technical assistance resources pre- and post-funding. NetWork Kansas estimates that it will provide technical assistance to 300 small businesses over the 5-year grant period and that 150 of these businesses will subsequently attract capital.  
  • American Samoa, approved for up to $57 million in SSBCI Capital funding, will operate four programs, including a loan guarantee program which will provide a partial guarantee to support surety bonds and lines of credit, and an equity/venture capital program which will make direct investments in local small businesses and projects. 

A full list of award descriptions for states receiving these funds is available here

To date, the Treasury Department has announced the approval of more than $135 million in technical assistance grants to 40 states and territories. In addition, the Department has announced the approval of state, territory, and Tribal government plans corresponding to more than $8.4 billion in funding under the SSBCI Capital Program to support small business and entrepreneurship and expand access to capital. 

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OCC to Host Office Hours in San Francisco

WASHINGTON—The Office of the Comptroller of the Currency (OCC) today announced the Office of Financial Technology (OFT) will hold Office Hours in San Francisco, May 21-22, 2024, to promote responsible innovation in the federal banking system.

Office Hours are one-on-one meetings with OCC’s OFT staff to discuss financial technology (fintech), new products or services, partnering with a bank or fintech company, or other matters related to responsible innovation in the federal banking system. OCC staff will provide feedback and respond to questions. Each meeting will be scheduled for 50 minutes.

Information on how to request a meeting is available on the Office Hours Event page. To be considered, submit a request by March 30, 2024. The OCC will provide specific meeting times to selected participants following a review of all requests.

The OCC is planning additional Office Hours in 2024.

OCC Assesses $250 Million Civil Money Penalty Against JPMorgan Chase Bank, N.A. Related to Bank’s Trade Surveillance Program

WASHINGTON—The Office of the Comptroller of the Currency (OCC) today announced a $250 million civil money penalty against JPMorgan Chase Bank, N.A. (JPMC) related to deficiencies in its trade surveillance program.

The OCC found that JPMC operated with gaps in trading venue coverage and without adequate data controls required to maintain an effective trade surveillance program. Generally, trading venues are systems or electronic platforms, operated by investment firms or market operators, that bring together multiple third party buying or selling interests in financial instruments to perform a transaction. The OCC expects banks to perform trade surveillance to monitor the market conduct of its traders and clients as part of its market conduct risk control framework. The OCC found that JPMC failed to surveil billions of instances of trading activity on at least 30 global trading venues. These gaps and deficiencies in JPMC’s trade surveillance program constitute unsafe or unsound banking practices.

The OCC also issued a cease and desist order requiring JPMC to take broad and comprehensive corrective actions to improve its trade surveillance program. The order requires the bank to correct the deficiencies, to seek the OCC’s non-objection before onboarding new trading venues, and to obtain an independent third party to conduct a trade surveillance program assessment.

The OCC’s enforcement actions are separate from, but coordinated with, the Board of Governors of the Federal Reserve System which announced a related enforcement action today against JPMorgan Chase & Co.

The OCC penalty has been paid to the U.S. Department of the Treasury.

Related Links

Treasury Sanctions Primeiro Comando da Capital (PCC) Operative

WASHINGTON — Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated Diego Macedo Gonçalves do Carmo (Gonçalves), a member of Primeiro Comando da Capital (PCC), a Brazil-based criminal organization sanctioned pursuant to counter narcotics authorities. The PCC is the most notorious organized crime group in Brazil and among the largest in Latin America, and Gonçalves is a key operative responsible for laundering hundreds of millions of dollars for the organization. 

“With an extensive network throughout Latin America, as well as an expanding global presence, the PCC represents one of the most significant narcotics trafficking organizations of concern in the region,” said Under Secretary of the Treasury for Terrorism and Financial Intelligence Brian E. Nelson. “The United States will continue to stand with Brazil and other partners in the region in our efforts to counter the PCC’s ability to operate, including its ability to launder illicit funds through the global financial system.” 

Today’s action would not have been possible without the cooperation of Brazilian law enforcement authorities. 

FOLLOW-UP DESIGNATION OF PCC OPERATIVE

Gonçalves is a Brazil-based member of the PCC. In November 2022, the Court of Justice of the State of São Paulo sentenced Gonçalves, along with other individuals, to seven years and 11 months in prison, on drug trafficking charges. According to the court, Gonçalves is responsible for laundering 1.2 billion Brazilian reals ($240 million) for the PCC. The judge who presided over the sentencing identified the defendants as members of the PCC and stated that they coordinated sectors of the criminal organization related to drug trafficking. Though incarcerated, Gonçalves remains active in PCC affairs, delivering instructions from behind bars.  

Additionally, Gonçalves was found to have participated in the robbery of a branch of Banco do Brasil in Uberaba, Brazil on June 27, 2019.

OFAC designated Gonçalves pursuant to Executive Order (E.O.) 14059 for being owned, controlled, or directed by, or having acted or purported to act for or on behalf of, directly or indirectly, the PCC.

Today’s action follows OFAC’s designation of the PCC on December 15, 2021, as part of the first tranche of designations under E.O. 14059, a new counter narcotics authority issued by President Biden to give Treasury greater flexibility, speed, and power to sanctions those within the global drug trade. Rising to prominence in São Paulo in the 1990s, the PCC has forged a bloody path to dominance through drug trafficking, as well as through money laundering, extortion, murder-for-hire, and drug debt collection. The PCC operates throughout South America and its operations reach the United States, Europe, Africa, and Asia.

SANCTIONS IMPLICATIONS

As a result of today’s action, all property and interests in property of the designated individual described above that are in the United States or in the possession or control of U.S. persons must be blocked and reported to OFAC. In addition, any entities that are owned, directly or indirectly, 50 percent or more by one or more blocked persons are also blocked. Unless authorized by a general or specific license issued by OFAC, or exempt, OFAC’s regulations generally prohibit all transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of designated or otherwise blocked persons. U.S. persons may face civil or criminal penalties for violations of E.O. 14059.

Today’s action is part of a whole-of-government effort to counter the global threat posed by the trafficking of illicit drugs into the United States that is causing the deaths of tens of thousands of Americans annually, as well as countless more non-fatal overdoses. OFAC, in coordination with its U.S. government partners and foreign counterparts and in support of President Biden’s National Drug Control Strategy, will continue to target and pursue accountability for foreign illicit drug actors.

The power and integrity of OFAC sanctions derive not only from its ability to designate and add persons to the SDN List, but also from OFAC’s willingness to remove persons from the SDN List consistent with the law. The ultimate goal of sanctions is not to punish, but to bring about a positive change in behavior. For information concerning the process for seeking removal from an OFAC list, including the SDN List, please refer to OFAC’s Frequently Asked Question 897 hereFor detailed information on the process to submit a request for removal from an OFAC sanctions list, please click here.

For more information on the individual designated today, click here.

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U.S. Treasury Statement on the IFC Bridge International Academies Case

The U.S. Treasury Department is profoundly concerned with the unacceptable failures at the IFC identified by the Compliance Advisor Ombudsman (CAO) in its investigation of the IFC’s Bridge International Academies project.  The investigative report (the “CAO Report”)[1] disclosed on March 14 confirmed numerous incidents of child sexual abuse between 2013 and 2020 at schools in Kenya run by Bridge International Academies (Bridge), a former IFC client.  The CAO also concluded that IFC’s failure to ensure Bridge’s compliance with IFC’s environmental and social risk mitigation policies (i.e., the Performance Standards) likely contributed to the severe harms inflicted on the abused school children.  

The IFC accepts the CAO’s investigation findings and over the last several months has been developing its plan to address the project-related harms, support the sexual abuse survivors and correct its institutional failures.  This Management Action Plan (MAP) was approved by the IFC Board on March 13 and disclosed alongside the CAO Report.  The United States welcomes President Banga’s call for an independent, external investigation of the CAO investigation and supports the MAP, highlighting the following.

Throughout this process, our immediate priority has been to address the harms suffered by the survivors and support their recovery.  We believe survivors should be central to determining the scope and focus of remediation. We therefore welcome the inclusion of consultation with survivors as a first step in the MAP to inform the final approach to providing a range of services to the survivors.  

These consultations should be the main driver for the design of the proposed remediation program. We believe IFC should keep all remedy options on the table while the consultations proceed.

To prevent similar harms from happening again in IFC financed projects, a key MAP commitment is for the IFC to release a zero-tolerance statement on inaction or reprisals related to gender-based violence and child protection issues.  We also welcome the proposed mandatory staff training and the protocol making clear that reporting and escalation of these issues within the IFC management structure are staff obligations, as well as the inclusion of anti-retaliatory policies to support early detection and remediation.  We also expect that updates on the implementation of this commitment will be included in the publicly disclosed MAP implementation reports and discussions with the IFC Board.

Finally, we are deeply troubled by the broader accountability issues raised by this case.  These include IFC’s agreement with Bridge to put in place a supplemental confidentiality agreement following the initiation of the CAO’s investigation.  To perform its role effectively, the CAO must be independent, and its investigations must be conducted free of interference and retaliation.  Even the perception that this independence is being undermined is troubling.  Reflecting these concerns, we reiterate our support for President Banga’s call for an independent, external investigation.

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