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The World Bank Tokyo Office Telephone: (03) 3597 6650

INTERNATIONAL BANK FOR RECONSTRUCTION AND DEVELOPMENT 10F, Fukoku Seimei Building Fax: (03) 3597 6695
INTERNATIONAL DEVELOPMENT ASSOCIATION 2-2-2, Uchisaiwai-Cho Cable: INTBAFRAD TOKYO
Chiyoda-ku, Tokyo 100, Japan
December 5, 2018

Dear People,
Yesterday was a long day; back online with a few thoughts. What did I forget to tell you?
That I am here in a dialogue with the critical mass of people that are reclaiming our world.
There is no getting around that. I will show you three things that I found online--these are
just part of our dialogue.

https://twitter.com/KarenHudes/status/1069395258939715586
https://twitter.com/KarenHudes/status/1067236847187836928
https://twitter.com/KarenHudes/status/1069755391393890304
I will show you screenshots, hopefully with active links at the end

Our discussion is going to continue. We are going to do our best to filter out the garbage and
disinfo that the Banking Cartel is trying to interject. The Banking Cartel is most unwelcome,
and what is more, we are going to wind them down.

https://youtu.be/qCdcXsormzk

The US-Japan Committee Under the Status of Forces is going to make sure
that the US will honor its defense pact with Japan. This is only possible
with the US monetary gold reserves in the Global Debt Facility. The
weakness of the Federal Reserve Note in terms of gold, along with the US
National War College's accurate power transition model, explains our
coalition.

The world's people are directing this coalition, and will retrofit any
decisions after a Global Currency Reset that will exchange the corrupt

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paper currencies issued by the Banking Cartel for the world's gold and for
local currencies issued by villages and towns.
There are many claims for restitution by people who have been harmed
by the Network of Global Corporate Control, including claims of
indigenous peoples, peoples harmed by colonialism, trading of their birth
certificates, peoples tortured by the Network of Global Corporate
Control, slavery, climate modification, peoples subjected to mind control
and other hidden DARPA technologies, people whose health has been
impacted by GMOs and other hidden carcinogens and toxins, hidden cures
for diseases, to list just a few claims. If it is left to the Board of
Governors to deal directly with these claims, there is going to be a huge
risk that we create an institution that oppresses.
How to compensate people who are holding Treaty of Versailles bonds
outside the Global Debt Facility is another claim in the list. I expect we
are going to have our hands full initially in helping people to understand
how necessary it is that we have a peaceful transition so that they thank
those 1%ers that are making the peaceful transition possible.
We will have the Global Currency Reset just as soon as the dufuses in the
Black Nobility have realized that a critical mass of humanity is not going
to back down (and neither am I).
Teleprompter:
https://s3.amazonaws.com/khudes/dctvteleprompt12.4.18.pdf

https://s3.amazonaws.com/khudes/Twitter12.2.18.2.pdf

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https://s3.amazonaws.com/khudes/Twitter12.18.1.pdf
https://www.scribd.com/document/394225247/The-Board-of-Governors-of-the-
World-Bank-and-IMF-Are-Ending-the-Corruption-in-the-World-s-Money-By-Replacing-
Worthless-Paper-Currency-for-Currency-Min

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Note how my replies were hidden by the 1 more reply buttons:

https://s3.amazonaws.com/khudes/dctvteleprompt12.4.18.pdf

Sincerely,
Karen Hudes
Acting General Counsel, International Bank for Reconstruction and Development
Overseer Mandate Trustee, Global Debt Facility, TVM-LSM-666

Attachments:
teleprompter for latest DCTV segment
contact information

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INTRO

Good evening, I am your host Karen Hudes. This show is a Series that has been coming
to you from DCTV since 2015 in a weekly program called the Network of Global
Corporate Control. Today’s program is called “For Whom the Bell Tolls” That is a quote
from John Donne: "No man is an Island, intire of it selfe... any mans death diminishes me,
because I am involved in Mankinde; And therefore never send to know for whom the bell tolls;
It tolls for thee. " The title of Earnest Hemingway's famous book about the Spanish Civil
War is "For Whom the Bell Tolls"

Thank you to DCTV, Carmen Stanley, Project Director; Maurice Jackson, Studio Director; and
Krushae Starnes, Audio and Prompter.

This Series is about the world's wealth, which was put into a trust managed by the Boards of
the World Bank and IMF at the end of WWII. Many of the things we talk about in this series
have been kept hidden from you. It is the central banks and the group directing the central
banks called the Black Nobility that have been hiding the truth from you.

I speak for a coalition that is in control of the world's wealth. The coalition also includes the
world's military powers. This coalition was predicted by an accurate power transition model
from the US national war college that came to me in the world bank's legal department in
2004. I mentioned this coalition the day after I wrote to the US Defense attaché in Tokyo.
Japan's military troops are an important part of this coalition. Yesterday I tweeted a
comment on an article in Veterans Today that I wrote in 2014. The US-Japan Committee
Under the Status of Forces is going to make sure that the US will honor its defense pact with
Japan. This is only possible with the US monetary gold reserves in the Global Debt Facility.
This graph shows the weakness of the Federal Reserve Note in terms of gold. This graph,
along with the US National War College's accurate power transition model explains our
coalition.

The unconstitutional Federal Reserve Note is simply an imposter -- the US Dollar is alive and
well, and living here, in the Global Debt Facility:
https://s3.amazonaws.com/khudes/Twitter12.3.18.pdf
The world's people are directing this coalition, and will retrofit any decisions after a Global
Currency Reset that will exchange the corrupt paper currencies issued by the Banking Cartel
for the world's gold and for local currencies issued by villages and towns.

There is another reason that our coalition is facing down the Banking Cartel. It is because
people do not want to be pushed around by corrupt bankers. That was true at the end of
WWII, when the world's wealth was deposited in the World Bank, and it is true today. It took
me several hours to show that the countries of the world insisted that they have a voice at the
World Bank and that was evident from a statement that the US Governor made to the
members of the world Bank in 1946. It took me hours to post this statement on the internet.
http://documents.worldbank.org/curated/en/326411468153863895/pdf/833530BR0Ban
k00Box0382087B00PUBLIC0.pdf

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I
have attached it to the memorandum which I gave the Board when I was reinstated as Acting
General Counsel:
https://s3.amazonaws.com/1947memo.pdf

Do not be put off if any of my statements seem unlikely. I can document all of my
statements, because they are all true. There are also electromagnetic weapons that affect
your ability to accept this information -- more than two-thirds of the people are very
susceptible to these weapons. The EMF scalar weaponsy were used in the Iraq war, and there
were stories about these weapons when they were used on some of the people at the US
Embassy in Cuba. I noticed that the brain imaging science sometimes shows up in magazine
articles:

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Information on mind control and advanced weapon experiments on civilians
https://s3.amazonaws.com/khudes/Twitter12.1.18.2.pdf

We the people are confronting the Banking Cartel in a fight to stay out of WWIII. We are
planning to wind down the Banking Cartel, which is bankrupt from the 2 quadrillion in Treaty of
Versailles bonds that were issued between WWI and II to some of the elite in exchange for their
gold. José Rizal and Ferdinand Marcos gathered most of these bonds into the Global Debt

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Facility. We have already heard from "Sir Ralph" who has two trillion worth of these bonds. Sir
Ralph offered to help solve Greece's financial problems with them.
https://s3.amazonaws.com/khudes/Twitter5.14.18.2.pdf

This is what I said to Sir Ralph (https://s3.amazonaws.com/khudes/Twitter7.25.15.pdf

So that you understand, the paper currency fiat system is coming down, and the Federal
Reserve system and the rest of the Bank for International Settlements and that giant
conglomerate referred to by Vitali, Glattfelder, and Battiston of ETH Zurich, as the
“super-entity” http://arxiv.org/PS_cache/arxiv/pdf/1107/1107.5728v2.pdf is in
receivership in the Global Debt Facility that holds the world’s wealth. Greece's and
other countries' debts are getting offset against the Treaty of Versailles bonds held by
the Global Debt Facility. There are many persons who are trying prevent the Board of
Governors of the Bretton Woods institutions from dismantling the Network of Global
Corporate Control. The Board of Governors of the Bretton Woods institutions
administers the Global Debt Facility.

The International Court of Justice, CIA, Committee of 300, and Ferdinand Marcos' son,
Tiburcio Villamor Marcos, to name a few, tried to steal the world’s monetary gold
reserves and other assets in the Global Debt Facility, and the Network of Global
Corporate Control keeps breaking link where I disclosed this:
https://s3.amazonaws.com/khudes/steal+gold2.pdf

The Board of Governors of the World Bank and International Monetary Fund is dealing
with the question about what to do with excess currencies held by speculators. They are
going to have to decide how to carve up the Network of Global Corporate Control's
subsidiaries when winding down that giant conglomerate.

There are many claims for restitution by people who have been harmed by the Network
of Global Corporate Control, including claims of indigenous peoples, peoples harmed by
colonialism, trading of their birth certificates, peoples tortured by the Network of Global
Corporate Control, slavery, climate modification, peoples subjected to mind control and
other hidden DARPA technologies,
https://s3.amazonaws.com/khudes/Twitter7.14.15.1.pdf , peoples whose health has
been impacted by GMOs and other hidden carcinogens and toxins, hidden cures for
diseases, to list just a few claims. The Network of Global Corporate control has been
killing those doctors who can restore people's health.

If it is left to the Board of Governors to deal directly with these claims, there is going to
be a huge risk that we create an institution that oppresses. If people can accept that the
Global Debt Facility will handle currency and Fukushima only, because we are facing
extinction if these problems are not solved, and leave the other issues to each peoples in
each country, we have a fighting chance. This is a dialogue, and I will do what I can to
further the dialogue. Sequencing will be key -- helping people get their health and
reasoning back so they can make informed decisions seems like a plan.

How to compensate people who are holding Treaty of Versailles bonds outside the
Global Debt Facility is another claim in the list. I expect we are going to have our hands
full initially in helping people to understand how necessary it is that we have a peaceful
transition so that they thank those 1%ers that are making the peaceful transition
possible. This difficult question of amnesty was debated here:
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https://s3.amazonaws.com/khudes/Twitter6.24.15.2.pdf and it is often raised in the
comments to me. It may just be that we never get around to compensating the elite still
holding the Treaty of Versailles bonds.

We the people are having a dialogue among ourselves about the Global Currency Reset.
You can see this dialogue in the archives of this Series on YouTube.

Many people are asking when we are going to start exchanging currencies. My answer:

We will have the Global Currency Reset just as soon as the dufuses in the Black
Nobility have realized that a critical mass of humanity is not going to back down (and
neither am I). https://s3.amazonaws.com/khudes/Twitter12.1.18.pdf

As I already told you, if the Banking Cartel were going to win, they
would have silenced me and kept me from speaking for our
coalition. I am obviously still getting through. That is what I mean
when I say that part of my job is to be a canary in the coalmine.
Miners would bring a canary with them into the coalmine to serve
as a warning. I am your canary in the coalmine. So long as I am
getting through, you know that the Global Currency Reset is on
track:

Of course it is taking time to deliver concrete results. We are


talking about a fundamental transformation, and the biggest
change is in our knowledge about what it means to be human and
how we deal with each other.

Another question that people have is how I got this job of being the lawyer for the Global
Debt Facility containing much of the world's wealth. The short answer is that I was in
the right place at the right time. The World Bank's Legal Department stands between
the Banking Cartel and the world's wealth in the Global Debt Facility. My reports of
corruption at the World Bank, and refusing to back down as the corruption kept getting

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deeper, helped the Boards of the World Bank and IMF, in charge of the Global Debt
Facility to notice me. Last week I tweeted the chronology in my 2011 testimony to the
European Parliament.

A cover-up at the apex of the international financial system must be


resolved https://s3.amazonaws.com/khudes/Twitter12.2.18.pdf
. …

https://www.scribd.com/document/394714671/The-Cover-up-of-Corruption-Twitter12-2-18

I also tweeted my reports to the world's accountants.

None of the accountants, none of them, were willing to admit their role in
any of this fraud and corruption I reported. The accountants did not add up.
https://s3.amazonaws.com/khudes/accounting1.pdf
https://www.scribd.com/document/394708933/Fraud-in-the-Accounting-Profession-Accounting-1

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I will attach this information to the teleprompter.

Two more points I want to make today in my prepared remarks. I am going to read you the
statement that Donald Trump failed to answer in my affidavit for the commercial lien in which I
bankrupted Donald Trump. When some people say that I did not get Donald Trump's attention,
I can assure you that I did, and I also got the attention of his legal team. How do I know this for
sure? Well, Nita Johnson tried to bribe me after Trump faked the elections, which were not
legal because the Constitution was not in effect. Trump is a liar and he is continuing to lie. He
was never duly elected by the American people because a military government was already
secretly in place, stealing all Americans' properties under war powers.
https://s3.amazonaws.com/khudes/dctvteleprompt3.21.17.1.pdf

27. Donald J. Trump has failed to acknowledge that the United States is not operating under
the Constitution of 1789 nor has he acknowledged that the US' monetary gold reserves are
administered by the Board of Governors of the World Bank and International Monetary
Fund because they are in a Trust established at the end of WWII by General Eisenhower and
President Truman. Instead, Donald Trump has perpetuated the hoax on the American
people, despite having had the opportunity to rectify these falsehoods
https://s3.amazonaws.com/khudes/trump1.pdf Donald Trump has harmed me personally
with these lies and falsehoods, as this has prevented me from returning to the World Bank's
headquarters and working on the Global Currency Reset agreed to by the Board of
Governors of the World Bank and IMF, and returning the Constitution of 1789 of the United
States via an Article V Constitutional Convention. "

Donald Trump failed to respond, and he is in default and owes me as Overseer Mandate
Trustee of the Global Debt Facility.

The last point I want to make is about title to property. This is an important point. The
Banking Cartel has stolen your property, all of it. When you register land and cars with
the state authorities, the title to all your property is now registered in the name of the
bankers. Youtube erased this information when I answered a comment, and so I will
give you the missing question and answer now.
[YouTube hid Mike Wilson's question behind this button: ]

Karen Hudes what about the titles for cars and the Deeds for homes those are also
fraudulent how are they planning to fix that?
http://freeamerican.com/Images/METROchapter1.pdf
In the old days before FDR ran this greatest of scams all the records of deeds and property
used to be filed in every state in what was known as The Great Register. It was during the
Roosevelt years that the Great Registers started to disappear from the keeping places in
the State. Under the "Emergency" and the bankruptcy, the land of property holding
citizens was claimed as collateral. All the Deeds and Titles were
taken. Nowadays you either get a Certificate of Deed, Warranty deed, or Deed in Trust
document when you get your property paid off. This is because you don't have true title to
your land or your home. The government holds all your property in trust because you
have been deemed "incompetent" under their law to manage your own affairs.

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When you buy a new car the MSO, which is technically the Bill of Sale from the manufacturer, is sent
to the State and the State issues you a Certificate of Title. The Certificate serves the same purpose
for your cars as it does for your real estate. People, you own nothing of major value that you think
you do. Even you and your labor are nothing but collateral to the bogus bankruptcy. When did you
stop being "personnel" and become a "human resource?" Folks, you don't even own the skin you live
in! You are economic slaves, in the absolute truest sense of the word, to the Federal reserve and the
International Bankers, and Metro

OUTTRO

We are not islands, we know we suffer a loss when anyone is harmed. We all care that
our brethren are exploited and oppressed. That is what will enable us to work our way
out of the Bankers' fractional reserve fiat money scam. Until next week, I am your host,
Karen Hudes

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The World Bank Tokyo Office Telephone: (03) 3597 6650
INTERNATIONAL BANK FOR RECONSTRUCTION AND DEVELOPMENT 10F, Fukoku Seimei Building Fax: (03) 3597 6695
INTERNATIONAL DEVELOPMENT ASSOCIATION 2-2-2, Uchisaiwai-Cho Cable: INTBAFRAD TOKYO
Chiyoda-ku, Tokyo 100, Japan
Sunday, December 2, 2018
Dear People,

In this tweet, I am showing you the chronology when I reported corruption at the World
Bank. I gave this chronology to the European Parliament and US Congress. I have gone up
the ladder, reporting the rot to all of the authorities, up to the Universal Postal Union, which
presides over the world's financial system.

The world's central banks owe us over 2 quadrillion dollars. I have recorded this debt with
the secretaries of state in the states where the US Federal Reserve has its branches. All of the
world's military powers are on board, and they are going to maintain the peace while we clean
up the corruption, and establish legitimate governments. Each of the respective people in the
world's countries are going to be in charge of reestablishing their legitimate governments.
We are not in a rush.

We now own all of the banks. All of the illegal governments are accountable to us, the people
of the world.

https://s3.amazonaws.com/khudes/Twitter6.7.15.2.pdf
To: Barnette, Jeffrey (OCFO)
Subject: FW: CONT Hearing May 25, 2011
Corruption/WorldBank/Whistleblower.mp4
http://www.youtube.com/watch?v=c7E9SUwlooE

Senior Counsel for the World Bank legal department reports corruption to US Congress, the
World Bank's other member countries, and the public.

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an online file
https://docs.google.com/file/d/0Bzss7Q0pShvzSk94eVUyWlpaVU0/edit?usp=sharing

Dear Mr. Barnette,

I would appreciate if you would inform members of the DC government about the
unresolved governance issues at the Bretton Woods Institutions that we discussed, because
as I mentioned, the World Bank will continue to decentralize jobs at headquarters to other
countries until the largest shareholder plays by the rules. The above version of my paper on
whistleblower protections in the EU went to the US Congress and the members of the
European Parliament Committee on Budgetary Control. The chronology (pages 24-34) did
not appear on the Committee's website for the public hearing on May 25, 2011.

http://www.europarl.europa.eu/document/activities/cont/201105/20110518ATT19540/20110
518ATT19540EN.pdf

Best,
Karen
Law Offices of Karen Hudes

From: karenhudes
To: christoph.nerlich@europarl.europa.eu
Subject: RE: CONT Hearing May 25, 2011
Date: Mon, 16 May 2011 08:04:14 -0400

Christoph,

Thank you so much for asking. A cover-up at the apex of the international financial system
must be resolved. An issuer of bonds on the capital markets may not remain out of
compliance, and its regulators must also be held accountable. The code of professional
responsibility for the legal profession is quite explicit under these circumstances. My
obligations as an economist familiar with the international monetary system also came into
play. I attach the stakeholder analysis which I mentioned in footnote 8.

Best,

Karen

Jacek Kugler, Ron Tammen and Brian Efird: “The War Presidency: Options Taken and
Lost”, International Studies Association Meetings, Montreal, Canada, published February
2004, available here:
http://citation.allacademic.com//meta/p_mla_apa_research_citation/0/7/4/2/7/pages74272/p7
4272-1.php

Corruption/WorldBank/Whistleblower.mp4

Go to YouTubePlay video

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Senior Counsel for the World Bank legal department reports corruption to US Congress, the
World Bank's other member countries, and the public.

00:11:17

Added on 4/12/11

267 views

Subject: RE: CONT Hearing May 25, 2011


Date: Mon, 16 May 2011 13:41:38 +0200
From: christoph.nerlich@europarl.europa.eu
To: karen hudes

Dear Karen,
thank you very much for your understanding.

What do you mean by "discharge my obligation" to US Congress. I would understand that


you are not directly accountable to the US Congress but you see this as your moral and
maybe professional obligation?

Best regards,

Christoph

From: Karen Hudes


Sent: 16 May 2011 12:45
To: NERLICH Christoph
Subject: RE: CONT Hearing May 25, 2011

Dear Mr. Nerlich,


Thank you for circulating the full version of the written contribution to the Members of
Parliament. I also appreciate your informing me that you have given this document to the
World Bank. I had provided an earlier version of the chronology to the World Bank and
possess documentation to substantiate all of the matters mentioned in the chronology.

I would also like to inform you that yesterday I hand delivered my full written contribution
to a senior official in the US Congress in order to discharge my obligation as a legal officer
of the World Bank to disclose these breaches in the World Bank's charter to its oversight
agencies.

I look forward to the hearing next week and hope that it will be possible to meet you.

Sincerely,

Karen
Law Offices of Karen Hudes

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Subject: RE: CONT Hearing May 25, 2011-part 2
Date: Mon, 16 May 2011 11:57:38 +0200
From: christoph.nerlich@europarl.europa.eu
To: karenhudes
CC: angelina.gros-tchorbadjiyska@europarl.europa.eu; carmen.castillo@europarl.europa.eu;
donella.boldi@europarl.europa.eu; ries.baeten@europarl.europa.eu

Dear Karen,

thank you for sending the slightly revised versions. I would like to inform you about the
recommendation of the Parliament's Legal Service which we will follow with regard to
publishing your written contribution:

- All Members of the European Parliament attending the hearing will receive a full version
of your written contribution.

- The version published (both printed version and version put on the internet) will need to be
redacted. The mentioning of Mr. Scott Bloch on page 7 of part 1 will need to be blackened.
Part 2 will be published in full. Part 3 will not be published at all.

I thank you very much in advance for your understanding. Please be assured that we were
aiming to strike an appropriate balance between the public interest in transparency on the
one side and any privacy interest of the persons concerned on the other. Furthermore, we
were advised by our Legal Service that we should inform the World Bank about the material
to be used at the hearing.

We look forward to an interesting hearing on whistleblowing next week. Please do not


hesitate to contact me in case of any question.

Best regards,

Christoph
Christoph NERLICH
European Parliament
Committee on Budgetary Control
RMD 02J040- Rue Wiertz 60 - 1047 Brussels
Tel. +322 283 26 35- Fax +322 284 49 07
christoph.nerlich@europarl.europa.eu

https://s3.amazonaws.com/khudes/fekete.pdf

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Chronology of Internal Control Lapses at the World Bank

Date Event

3/17/00 Ms. Hudes, Senior Counsel in the Legal Department of the World Bank,
advised Vinay Bhargava, Country Director for the Philippines, to inform
Government of the Philippines that the World Bank could not disburse the
second and third tranches of the Banking Sector Reform Loan. Ms. Hudes
wrote a draft letter to be sent to Mr. Pardo, Secretary Department of
Finance, explaining that the investment advisors had cautioned that the
conditionality requiring the transparent sale of a controlling interest in
Philippine National Bank (the second largest bank in the Philippines) to a
strategic private investor could no longer be met after Lucio Tan’s purchase
of PNB shares. An article in the Business World appeared on that date
entitled “PNB sell-off controversy no longer a condition for bank sector
reform loan.” Lucio Tan owned Philippine Airlines, a major borrower of
PNB’s

6/6/00 Ms. Hudes reiterated her advice to Vinay Bhargava and Hemant Shah that
the loan conditionality in the BSRL was not met

6/15/00 Vinay Bhargava requested Mohan Gopal to reassign Ms. Hudes from
working on the Philippines portfolio

6/28/00 Jemal-ud-din Kassum, Vice President for East Asia Region, overruled
Vinay Bhargava’s recommendation to disburse second tranche of the
Banking Sector Reform Loan, following Ms. Hudes’ advice that a waiver
from the Board was needed for the tranche release conditionality, which had
not been met.

9/1/00 Ms. Hudes reported misconduct of Mohan Gopal to Ms. Anita Baker,
Ethics Officer. Mr. Gopal wrongfully refused to exonerate Ms. Hudes after
Mr. Gopal erroneously reported to senior management in the Legal
Department that there was an ongoing investigation in the Ethics Office.
The investigation had been called off months earlier because Ms. Hudes’
Statement of Expenditure did not have any significant discrepancies, all of
which had been fully disclosed. Mr. Gopal was placed on mandatory
administrative leave the following month.

9/28/00 Ms. Hudes protested being reassigned from the Philippines. In an email to
Douglas Webb (manager in the Legal Department) Ms. Hudes stated that
the Legal Department cannot fulfill its mandate if its lawyers have to worry
about reassignment for taking an independent position.

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10/00 The Government of the Philippines loaned $493 million to PNB after
depositors made heavy withdrawals.

11/15/00 Ms. Hudes was placed on a performance improvement plan based upon Mr.
Gopal’s retaliatory Overall Performance Evaluation (OPE).

6/30/01 The Philippines Banking Sector Reform Loan was cancelled without
disbursement of the second and third tranches aggregating $200 million; the
$200 million undisbursed balance of the Japan Eximbank cofinancing was
also cancelled.

12/6/01 In a meeting with James Wolfensohn and Pieter Stek, the Executive
Director (ED) for the Netherlands, Ms. Hudes informed James Wolfensohn
about the Philippines Banking Sector Reform Loan. During the meeting
James Wolfensohn said that Wilmer, Cutler and Pickering, the Bank’s
outside counsel, should investigate the BSRL; instead James Wolfensohn
told Ko-yung Tung, General Counsel, that Ms. Hudes had reported to him
that she was being retaliated against. Apparently Mr. Wolfensohn failed to
raise the BSRL with Wilmer, Cutler and Pickering.

7/10/02 Jacquelyn Gates, Ethics Officer after Ms. Baker, advised Kathy Sierra, VP
Human Resources, to intervene to end the retaliation by the Legal
Department, but Kathy Sierra refused

11/25/02 Ms. Hudes requested the Evaluation Department to revise the Bank’s
satisfactory rating in the Implementation Completion Report for Bank
supervision of the Philippines Banking Sector Reform Loan.

12/13/02 Ms. Hudes sent email to James Wolfensohn informing him that INT had not
opened an investigation although this had been requested by Jacquelyn
Gates, Ethics Officer, and that the Evaluation Department had refused to
correct its inaccurate report to the Board on Bank performance on the
BSRL.

1/8/03 INT refused to honor Jacquelyn Gates’ 10/31/02 request for an investigation
into whether Ms. Hudes had been retaliated against, stating that it had no
jurisdiction because allegations of wrongdoing were made to INT after the
retaliation had occurred. There was no response to Ms. Hudes’ argument
that previous allegations of Mr. Gopal’s misconduct to the Ethics Office on
6/26/00, 9/1/00 and to management of the Legal Department on 8/8/00 fell
within the definition of retaliation in the World Bank's Staff Rule 8.01.
This Staff Rule was later revised on June 10, 2008 to incorporate an explicit
whistleblower policy. The policy did not follow the requirement for access
to external arbitration mandated under US appropriations legislation. Its
weak provision for independent investigations was not observed in Ms.

2
Hudes' case. The external reviewer was appointed by the Ethics office
although the Ethics office was implicated in Ms. Hudes' case. The Ethics
office permitted Mr. Gopal to give Ms. Hudes a retaliatory evaluation on
the eve of his departure from the Bank on mandatory administrative leave
after Ms. Hudes' report of Mr. Gopal's misconduct. The Ethics office also
permitted tampered documentation concealing Ms. Hudes' illegal
separation from the Bank to be used in the Bank's conflict resolution
system. The Ethics office also permitted the Bank's health office to contact
Ms. Hudes' physicians without her consent. The external reviewer ignored
four letters from the US Congress requesting a review and report and held
that Ms. Hudes was not a whistleblower in an evident device to avoid
application of the ineffectual whistleblower regime in the World Bank. Ms.
Hudes was counseled by one of the World Bank's Ethics Officers and the
Deputy General Counsel of the IMF that the World Bank's whistleblower
regime was ineffectual.

2/28/03 Ms. Hudes sent the Implementation Completion Report for the Philippines
Banking Sector Reform Loan and her comments thereon to William Holder,
Deputy General Counsel of the IMF. The IMF was involved with the
Philippines Banking Sector. Mr. Holder confirmed Ms. Hudes’ analysis of
what had happened on the BSRL, but advised her to drop the matter
because it would be difficult for her to prevail. Instead on March 4, 2003 he
sent a reference to Pat Neill and Elizabeth Adu, “I regard Ms. Hudes as a
distinguished professional whose substantial contribution in the field over
many years deserves recognition.”

3/20/03 Todd Crawford of US ED’s office sent email that Jacquelyn Gates’ decision
to resign from the Bank was “made as a result of considerable frustration.”
Bob Holland, U.S. Alternate, and Todd Crawford “came away from our
meeting [with Jacquelyn Gates] with certain concerns that we have shared
with both the Audit Committee and senior management.”

10/2/03 Ms. Hudes discussed World Bank compliance issues with Jacquelyn Gates
and Anita Baker at Annual Conference of the Ethics and Compliance
Officer Association held in Orlando, Florida

6/2/04 Ms. Hudes requested the Audit Committee to look into lapses in the Bank’s
internal control system on the Philippines Banking Sector Reform Loan.

6/4/04 Elizabeth Adu, Deputy General Counsel, sent a letter informing Ms. Hudes
that she violated the policy on communications with EDs, whereby
correspondence from staff on business issues is routed through the VP and
not directly to the EDs.

11/16/04 Ms. Hudes was placed on a Performance Improvement Plan for a trip to
Nigeria which was approved under normal Bank procedures.

3
1/13/05 Mr. Robert-Jan Sieben of Netherlands Ministry of Foreign Affairs
confirmed Pieter Stek’s meeting of 12/6/01 with Mr. Wolfensohn and Ms.
Hudes, and stated: “We feel that your allegations should be put on the
agenda of the Bank’s Audit Committee and be discussed there. We
requested our constituency office to be represented at such a meeting.”

11/2/05 INT's Report to Audit Committee concluding that Ms. Hudes was not a
whistleblower and was not subjected to retaliation, based upon 10/31/05
report of Douglas Herbert, consultant appointed by the INT, which
obfuscated the issues by focusing on the Nigeria Micro Small and Medium
Enterprise Project rather than the Philippines BSRL. The single issue on
the MSME Project raised by Ms. Hudes for the Audit Committee was
whether the Board was misled during its 12/16/03 discussion concerning
ownership of the Nigerian Government for the design of that Project.

11/4/05 Administrative Tribunal held that the Legal VPU failed to follow the
procedural requirements of the Staff Rules, defaming Ms. Hudes in the
process by publishing Mr. Gopal’s spurious allegations of fraud and his
retaliatory evaluation.

1/26/06 Memorandum of Understanding was signed, but the MOU was breached on
February 3, 2006 when Mr. Freestone, her new supervisor, was included in
a Management Review Group that referred to the Performance
Improvement Plan in confirming Ms. Hudes’ 2005 OPE. The Legal Vice
Presidency used white-out to obscure the Management Review Group’s
breach of the MOU in its submission to the Administrative Tribunal. Mr.
Freestone reassigned and cancelled projects that Ms. Hudes task managed,
canceled her supervision missions, and prevented other projects from being
approved. He also obstructed Ms. Hudes’ transfer to other departments by
calling said departments to make negative remarks and by undermining the
proposed global partnership on rule of law.

5/8/06 Denise Grant of Russell Reynolds interviewed Ms. Hudes for the General
Counsel position. During that interview, Ms. Hudes provided Ms. Grant
with the recommendation of William Holder, Deputy General Counsel of
the IMF. Pieter Stek was former Chair of the Board’s Committees for
Audit and Development Effectiveness, and Executive Director of the
Netherlands Constituency. His affidavit on Ms. Hudes’ case in the
Administrative Tribunal was also provided: “In a multilateral institution
which should be governed by the rule of law and high standards of probity
the charge of concealment from the Board of Executive Directors of
information relevant to the exercise of its duty of supervising management
and the persecution of the person who brings this to light is extremely
serious. If correct, which I believe, this poisonous cocktail undermines
good governance and ultimately the effectiveness of the Bank in fulfilling
its mandate. I shall continue to assist Ms. Hudes in her efforts to have due
process brought to bear, preferably by the Bank itself, on these issues of

4
governance.”

1/11/07 The President and Executive Director of the American Bar Association met
with Ms. Hudes concerning a global partnership on rule of law under the
Bank’s Global Partnership Program; Sweden’s International Legal
Assistance Consortium and Holland’s Center for International Legal
Cooperation agreed to collaborate with the ABA on February 1, 2007.

2/8/07 and Ms. Hudes advised Messrs. Eckhard Deutscher, German Executive Director
2/9/07 and Dean of the Board; and Svein Aass, Nordic Executive Director and
Chair of the Committee on Governance, that the global partnership on rule
of law was being sabotaged.

2/16/07 Ms. Hudes advised Mr. La Via, the Bank’s Chief Financial Officer, that his
refusal to provide Russell Reynolds’ report to Ana Palacio, the Bank’s
General Counsel, on grounds of confidentiality, was incorrect. “Under the
Bank’s COSO (auditing) Framework, those aspects of the Russell Reynolds
report which concern this matter of corporate governance are required to be
fully disclosed so that ongoing internal control lapses can be properly
resolved.”

2/23/07 Ms. Robin Cleveland, Counsellor to Mr. Wolfowitz, sent email to Ms.
Hudes, copied to Ms. Palacio, refusing to engage on outstanding
governance issues, stating: “I am copying your managers on this email in
order to have them address the matters with you as appropriate.”

3/1/07 Mr. Freestone informed Ms. Hudes that she had not been keeping him
informed of projects that she was pursuing, and that additional instances
may result in summary dismissal.

3/8/07- Meetings with Nilmini Rubin, Jay Branegan and James Greene, Senate
4/11/07 Foreign Relations Committee, regarding internal control lapses within the
Bank

5/21- Ms.Hudes sent emails to Patrick Grasso, Independent Evaluation Group,


6/8/07 requesting end to the cover-up on the Philippines Banking Sector Reform
Loan.

5/10- Ms. Hudes sent emails to Graeme Wheeler, Managing Director, requesting
6/22/06 end to cover-up and retaliation as well as compliance with Senate Foreign
Relations Committee request for documentation.

6/15/07 Ms. Hudes sent email to Dean of Board, Chair of Board Committee on
Governance and ED’s Administrative Matters; Audit Committee; Personnel
Committee; Ethics Committee; and Committee on Development
Effectiveness (“CODE”), copied to US ED and Alternate EDs concerning

5
whistleblower retaliation, and an end to the cover-up.

7/6/07 Memorandum to Mr. Robert Zoellick, requesting his support for


Ms. Hudes’ transfer out of Legal Department and an end to retaliation.

7/10/07 Email from Cathy Cardona, Manager Human Resources, refusing to comply
with Keith Luse’s request to provide the President of the Bank with a
transcript of Denise Grant's briefing on Ms. Hudes’ candidacy for General
Counsel.

7/12/07 Email to Jiayi Zou, copied to members of Board CODE, requesting interim
protection for whistleblowers, and end to cover-up on Philippines BSRL,
followed up by meeting on July 13, 2007.

7/23/07 Meeting with Robert Zoellick and the Legal Vice Presidency. Ms. Hudes
asked Mr. Zoellick how he expected to get a clean audit of the Bank’s
internal controls, and Mr. Zoellick asked if there were a Sarbanes-Oxley
problem in the Bank. When Ms. Hudes informed Mr. Zoellick that this was
indeed the case, Mr. Zoellick asked her to help correct the internal control
lapses. Mr. Zoellick’s office later referred the matter back to Ms. Ana
Palacio, the Bank’s General Counsel.

7/25/07 Ms. Hudes advised Mr. Mitchell, Head of Development Communications


Unit in EXT, that Ms. Palacio was trying to sabotage Ms. Hudes’ transfer to
EXT.

7/26/06 Ms. Hudes asked Mr. Zoellick to permit her to transfer to EXT in order to
work on the global partnership for rule of law.

7/27/07 Meeting with Mr. Sven Aass, Executive Director for the Nordic Countries.
Mr. Paul Volcker updated the Board on 7/23/07 on the investigation of INT
that did not address INT’s independence or integrity issues.

7/30/07 Ms. Hudes asked Whitney Debevoise, Executive Director, to provide


whistleblower protection by informing the head of the Bank’s mediation
office, Ms. Deborah Laufer, that Ms. Hudes was about to transfer from the
Legal Vice Presidency to the Development Communications unit of EXT.

8/2/07 Ms. Hudes denied access to the Main Complex when the Security Office
improperly refused to issue her retiree ID card. The ID card was
subsequently issued on 9/14/07. After the Board requested Ms. Hudes'
reinstatement on 8/20/09, the retiree ID card was revoked again without
cause.

4/17/08 Senators Richard Lugar, Patrick Leahy, and Evan Bayh requested the US

6
Government Accountability Office to carry out a study to assess whether
the World Bank's criteria for measuring the success of its projects are
ensuring the effective use of public funds, and whether Bank programs are
being hampered by internal resistence to increased transparency and
accountability.

10/10/08 Letter from France's Ambassador, Pierre Vimont, "I have received a copy of
your remarks on World Bank gouvernance and I thank you for this
transmission. But as I am not competent on such issues, I can only forward
your memorandum to Ambroise Fayolle and his staff."

10/21/08 Letter from Canada's Ambassador, Michael Wilson, "I note that you have
kept the Canadian Executive Director's office informed of developments.
The Executive Director's office is the appropriate responsibility center for
keeping Canada informed of this matter."

11/3/08 Letter from Australia's Ambassador, Dennis Richardson, "I am informed


that the Australian Executive Director to the World Bank, Dr Jim Hagan, is
aware of your concerns and is considering the best way to proceed with the
issues raised in your correspondence."

11/17/08 On 9/8/08 Mr. Chris Van Hollen, Congressman, wrote to Ms. Hudes, "Your
letter to Speaker Pelosi regarding your termination from the World Bank
was forwarded to me because I am the Member of Congress representing
Maryland's Eighth Congressional District, in which you reside." Letter
from Mr. Van Hollen to the World Bank requesting a review and report
concerning Ms. Hudes' relationship with the World Bank.

2/28/09 In a meeting Ms. Hudes requested A. Almofadhi, chair of the Board's Audit
Committee, to require an external audit of IBRD's internal control over
financial reporting.

6/8/09 Ms. Hudes discussed internal control lapses on Philippines Banking Sector
Reform Loan with M. Hasan, chair of the Board's Ethics Committee.

6/9/09 Audit Committee appointed KPMG to audit IBRD's internal control over
financial reporting.

8/6/09 Ms. Hudes sent S. Aass, chair of the Board's Committee on Governance and
Administration, an email: "The Board was never informed of the World
Bank's failed supervision on the Philippines Banking Sector Reform Loan. I
was fired in retaliation for trying to preserve the authority of the Board
under the Articles of Agreement. HRS has misinformed the US authorities
about the terms of my illegal separation from the World Bank. The Board
has never considered INT's or the Office of Ethics and Business
Conduct's role in perpetuating the cover-up to the Board of Executive

7
Directors. EBC is now violating the Bank's whistleblower policy by
conducting a review of its own malfeasance. The World Bank's conflict
resolution system is unable to resolve these corporate governance issues
involving the mandate of the Board of Executive Directors. Staff are too
intimidated to report misconduct after I was fired illegally. I attach relevant
documentation and would appreciate your assistance in bringing these
issues before COGAM for proper resolution."

8/20/09 Mr. Aass met with Ms. Hudes and reinstated her as an Advisor to the High
Level Commission on World Bank Governance and Acting General
Counsel. Mr. E. Miagkov met with Ms. Hudes and concurred with this
decision on behalf of A. Kvasov, Dean of the Board.

8/25/09 Ms. Hudes sent an email to Messrs. Aass and Miagkov that she had emailed
the High Level Commission on World Bank Governance: "During a
meeting on August 20th, Mr. Aass informed me that he took the view as
Chair of COGAM that the Board's mandate needs to return to
the original powers set out in the World Bank's Articles of Agreement in
order to address outstanding governance problems, and that the 1947
memorandum circumscribing the Board's authority to take the initiative was
no longer appropriate. It is my understanding that Mr. Miagkov supports
this view as well."

9/2/09 The World Bank barred Ms. Hudes from entering its headquarters
buildings.

10/13/09 Ms. Hudes commenced litigation against IBRD for violation of the US
securities laws in IBRD's retaliation against Ms. Hudes when she informed
the US Congress of corporate governance irregularities at IBRD. After
KPMG failed to follow Generally Accepted Accounting Standards in
auditing IBRD's internal control over financial reporting, on 8/26/10, Ms.
Hudes joined KPMG in the lawsuit.

12/10/09 Letter from Susanna Moorehead, UK Executive Director, in response to Ms.


Hudes' letter to Ambassador Sheinwald: "In Mr. Paulssen's unilateral
decision to suspend the [World Bank Administrative Tribunal] proceedings
on my case, he has allowed the [Ethics and Business Conduct office] to
complete an ultra vires investigation designed to discredit me in violation of
the World Bank's whistleblower policy. This undermines the World Bank's
ethics, the mandate of the Board of Executive Directors, and the right of
World Bank staff to report securities law violations and corruption without
fear of retaliation." Ms. Moorehead responded, "I have noted the contents
of your letter and attachments."

2/2/10 Ms. Hudes advised Jason Waskey, Maryland Director of President Obama's
Organizing for America, "I have been working with the Maryland
Delegation in Congress on some issues." Jason emailed in response on

8
March 2, "I just wanted to let you know that I've sent your packet on to the
appropriate people, and am waiting to hear back." In a phone conversation
on March 9th, Jason advised Ms. Hudes that bipartisan support on rule of
law at the World Bank would be welcome.

3/10/10 Senator Lugar issued a report, The International Financial Institutions: A


Call for Change A Report to the Committee on Foreign Relations,
http://www.foreignpolicy.com/files/fp_uploaded_images/int_fin_inst2.pdf
On page 24 of the report, Senator Lugar revealed that GAO had stated in
March 2009 that it could not carry out the study requested by Senator Lugar
to determine whether IBRD programs are being hampered by internal
resistance to increased transparency and accountability "because of
challenges we recently faced in gaining access to World Bank officials."

5/27/10 Ms. Hudes informed the US National Advisory Council on International


Monetary and Financial Policies consisting of the Secretaries of the
Treasury, State Department, Commerce, Chairmen of Board of Governors
of the Federal Reserve System, US Export Import Bank, and SEC,
Administrator of US Agency for International Development and US Trade
Representative that: "The Senate and House of Representatives intended to
protect persons who assist the legislature in oversight of the International
Bank for Reconstruction and Development against retaliation, and the
employee protection provisions of Title VIII of the Sarbanes-Oxley Act of
2002, Section 806, repealed in part IBRD's temporary exemption from the
US securities laws."

7/30/10 Letter from Jean-Louis Rioda, Acting Head of EC's Anti-Fraud Office,
OLAF: "I hereby acknowledge receipt of your correspondence received on
18/05/2010 in which you provide OLAF with information regarding 'the
impaired ethics and legal functions in the World Bank'. The information
has been evaluated, but unfortunately the European Anti-fraud Office
(OLAF) is not competent in this matter."

9/1/10 Ms. Hudes informed the National Advisory Council that KPMG failed to
comply with Generally Accepted Auditing Standards in conducting the
audit of IBRD's internal control over financial reporting commissioned by
IBRD's Audit Committee. The NAC has authority to remove IBRD's
temporary exemption from the US Securities laws.

9/15/10 In hearings on the World Bank's capital increase, the Senate Committee on
Foreign Relations stated that the GAO inquiry into transparency at the
World Bank had to be completed and necessary reforms in place before
appropriated funds for a capital increase would be disbursed.
http://foreign.senate.gov/hearings/hearing/?id=33c66777-5056-a032-525a-
a0a5806634e9

9
9/28/10 Ms. Hudes discussed IBRD's internal control lapses in a meeting with Barry
Collins, Principal Intelligence Officer of the UK's Serious Fraud Office, but
the U.S. Securities and Exchange Commission declined to provide any
information to the SFO on 10/12/10 when Mr. Collins called Mr. Arevalo,
Assistant Director, Enforcement Matters, Office of International Affairs, to
follow up.

11/28/10 Ms. Hudes reported to Carlos Braga, Acting Executive Secretary of the
Joint Ministerial Committee of the Boards of Governors of the Bank and the
Fund On the Transfer of Real Resources to Developing Countries, that "the
Board of Governors is required to fulfill its mandate under the Articles of
Agreement in order to provide strategic guidance and shareholder oversight
when information is concealed from the Board of Executive Directors and
this will impair IBRD's access to the capital markets."

12/2/10 Ms. Hudes followed up with a letter to the Board of Governors that "it is
necessary for the Board of Governors of the World Bank to provide
strategic guidance and shareholder oversight when information is concealed
from the Board of Executive Directors. The President, officers and staff of
the International Bank for Reconstruction and Development, in the
discharge of their offices, owe their duty entirely to the Bank and to no
other authority."

10
List of Acronyms and Bodies

ABA The American Bar Association, a professional organization of


lawyers

Audit Committee A standing committee of the World Bank's Board of Executive


Directors established to assist the Board in oversight of the World
Bank's finances, accounting, risk management and internal controls

Board of Governors Each of the World Bank’s 187 member countries is represented on
the Board of Governors by a government official, usually its
Minister of Finance or Minister of Development. Under the
Articles of Agreement, all powers of the IBRD are vested in the
Board of Governors

BSRL Banking Sector Reform Loan, $300 million loan from the World
Bank for reform of the financial sector in the Philippines following
the East Asia financial crisis, with a matching $300 million loan
from Japan.

CODE Board of Executive Directors Committee on Development


Effectiveness

COGAM Committee on Governance and Executive Directors'


Administrative Matters, a standing committee established to assist
the World Bank's Board of Executive Directors on issues related to
the governance of the institutions of the World Bank Group, the
Boards’ own effectiveness, and the administrative policy
applicable to Executive Directors’ offices

COSO Committee of Sponsoring Organizations of the Treadway


Commission (the US accounting regime, less stringent than the
Generally Accepted Accounting Principles and Standards normally
applied on the capital markets)

Development Joint Ministerial Committee of the Boards of Governors of the


Committee Bank and the Fund On the Transfer of Real Resources to
Developing Countries, a forum of the World Bank and the
International Monetary Fund established in 1974 to facilitate
intergovernmental consensus-building on development issues

ED Executive Director

Ethics Office Office of Ethics and Business Conduct

EXT World Bank's External Affairs, or public relations department

11
GAO US Government Accountability Office, Congress' auditors

HR Human Resources

High Level Com- Commission appointed by Robert Zoellick, President of the


mission on World World Bank, chaired by former Mexican President Ernesto Zedillo,
Bank Governance which recommended controversial reforms in the World Bank's
Governance in October 2009, including elimination of the Board of
Executive Directors of the World Bank. Germany's representative
resigned from the High Level Commission.

IBRD International Bank for Reconstruction and Development. The


original institution established at the Bretton Woods Conference,
which makes loans to middle-income countries for financing of
development projects, or to provide quick-disbursing loans for
policy lending with conditionalities

ID Identification card

IMF International Monetary Fund

INT Institutional Integrity Department, the World Bank's anti-fraud


agency. The abuses of INT are now public knowledge.
http://www.whistleblower.org/press/press-release-archive/484-bar-
complaintcharges-former- world-bank-official- with-ethics-
violations

KPMG An audit, tax and advisory firm

MoU Memorandum of Understanding

MSME Micro Small and Medium Enterprise

NAC US National Advisory Council on International Monetary and


Financial Policies consisting of the Secretaries of the Treasury,
State Department, Commerce; Chairmen of Board of Governors of
the Federal Reserve System, US Export Import Bank, and SEC;
Administrator of US AID and US Trade Representative

OLAF Office Lutte Anti-Fraude, the European Union's anti-fraud office

OPE Overall Performance Evaluation

PIP Performance Improvement Plan

12
PNB Philippines National Bank

Sarbanes-Oxley Securities legislation enacted after Enron to strengthen corporate


governance and provide greater information to shareholders on
capital markets

SEC Securities and Exchange Commission, the US regulatory agency


that oversees the stock markets

SFO Serious Fraud Office, the UK anti-fraud agency

Staff Rule 8.01 Staff Rule on Disciplinary Proceedings. Section 2.03 prohibits
retaliation against any person who in good faith provides
information about suspected misconduct.

VPU Vice Presidency Unit

Wilmer, Cutler and Outside counsel to the World Bank in 2000


Pickering

13
Persons

Svein Aass Nordic Executive Director and Chair of the World Bank Board’s
COGAM
Elizabeth Adu Deputy General Counsel of the World
A. Almofadhi Chair of the Board's Audit Committee
Mr. Arevalo SEC's Assistant Director, Enforcement Matters, Office of
International Affairs
Anita Baker Ethics Officer, received a report of misconduct of Mohan Gopal by
Ms. Hudes on 1 September 2000; succeeded by Ms. Gates, Ms.
Borrero, and later Ms. Taylor
Evan Bayh US Senator
Vinay Bhargava Country Director for the Philippines
Carlos Braga Acting Executive Secretary of the Development Committee (Joint
Ministerial Committee of the Boards of Governors of the Bank and
the Fund On the Transfer of Real Resources to Developing
Countries), replaced by Jorge Familiar, former ED for Mexico
Jay Branegan Staffmember on the US Senate Foreign Relations Committee
Cathy Cardona Manager Human Resources, refused to comply with Keith Luse’s
request to provide the President of the Bank with a transcript of
Denise Grant's briefing on Ms. Hudes’ candidacy for General
Counsel
Ms. Robin Cleveland Counsellor to Mr. Wolfowitz
Barry Collins Principal Intelligence Officer of the UK's Serious Fraud Office
Todd Crawford Official at the US Executive Director’s office, sent email that
Jacquelyn Gates’ decision to resign from the Bank was “made as a
result of considerable frustration.”
Whitney Debevoise Executive Director for the US
Eckhard Deutscher Executive Director for Germany, Dean of the Board
Jorge Familiar former ED for Mexico, replaced Carlos Braga as Executive
Secretary for Development Committee following Ms. Hudes' letter
to Board of Governors,
Ambroise Fayolle France’s ED
Mr. Freestone New supervisor of Ms. Hudes,, was included in a Management
Review Group
Jacquelyn Gates Ethics Officer after Ms. Baker
Mohan Gopal Boss of Ms. Hudes , asked by Mr. Bhargava to reassign Ms. Hudes
from working on the Philippines portfolio
Denise Grant Worked at Russell Reynolds, interviewed Ms. Hudes for the
General Counsel position
Patrick Grasso Staffmember of the Independent Evaluation Group
James Greene Staffmember on the US Senate Foreign Relations Committee
Jim Hagan The Australian Executive Director to the World Bank
Douglas Herbert Consultant appointed by the INT
William Holder Deputy General Counsel of the IMF
Bob Holland U.S. Alternate Executive Director

14
Karen Hudes Senior Counsel in World Bank's Legal Department for 20 years,
reinstated on 8/21/09 by decision of S. Aass and E. Miagkov as
legal advisor to the High Level Commission on World Bank
Governance and Administrative Matters ("COGAM") and Acting
General Counsel and barred from World Bank's headquarters the
following week
Jemal-ud-din Kassum Vice President for East Asia Region
A. Kvasov Dean of the World Bank's Board of Executive Directors
Deborah Laufer Head of the Bank’s mediation office
Patrick Leahy Senator
Richard Lugar Most senior Republican Senator, former chair of the Senate
Committee on Foreign Relations, author of the report, "The
International Financial Institutions: A Call for Change. A Report to
the Committee on Foreign Relations United States Senate"
Keith Luse Senator Lugar's staffmember on the Senate Committee on Foreign
Relations. Requested Ms. Cardona to provide the President of the
Bank with a transcript of Denise Grant's briefing on Ms. Hudes’
candidacy for General Counsel
Eugene Miagkov Alternate Executive Director for Russia
Mr. Mitchell Head of Development Communications Unit in EXT, was
informed by Ms. Hudes that Ms. Palacio was trying to sabotage
Ms. Hudes’ transfer to EXT
Susanna Moorehead UK Executive Director
Pat Neill A manager in the Human Resources Department
Ana Palacio The Bank’s former General Counsel. Tried to sabotage Ms. Hudes’
transfer to EXT
Mr. Pardo Secretary Philippines Department of Finance
Dennis Richardson Australia's Ambassador
Jean-Louis Rioda Acting Head of unit of the European Commission’s Anti-Fraud
Office, OLAF
Nilmini Rubin Staffmember on the US Senate Foreign Relations Committee
Hemant Shah Task team leader on the BSRL
Sheinwald UK's Ambassador to US
Robert-Jan Sieben Official at the Dutch Ministry of Foreign Affairs
Kathy Sierra Vice President Human Resources, advised by Ethics Officer Ms.
Gates to intervene to end the retaliation by the Legal Department,
but she refused
Pieter Stek former Chair of the Board’s Committees for Audit and
Development Effectiveness, and Executive Director of the
Netherlands Constituency
Lucio Tan Owner of Philippine Airlines, a major borrower of PNB, who
purchased PNB shares
Ko-yung Tung former General Counsel
Chris Van Hollen Member of Congress representing Maryland's Eighth
Congressional District, in which Karen Hudes resided

15
Pierre Vimont France’s ambassador (now deputy secretary general of the EU’s
foreign affairs branch)
Jason Waskey Maryland Director of President Obama's Organizing for America
Douglas Webb Manager in the Legal Department where Ms. Hudes worked
Graeme Wheeler Managing Director of World Bank
Michael Wilson Canada's Ambassador
James Wolfensohn Former President of the World Bank
Robert Zoellick President of the World Bank
Jiayi Zou ED for China, Chair of CODE , addressee of a request for interim
protection for whistleblowers and an end to cover-up on
Philippines BSRL

- *-

Governance World Bank

The World Bank is like a cooperative, where its 187 member countries are shareholders.
The shareholders are represented by a Board of Governors, who are the ultimate policy
makers at the World Bank. Generally, the governors are member countries' ministers of
finance or ministers of development. They meet once a year at the Annual Meetings of
the Boards of Governors of the World Bank Group and the International Monetary Fund.

Because the governors only meet annually, they delegate specific duties to 25 Executive
Directors, who work on-site at the Bank. The five largest shareholders, France, Germany,
Japan, the United Kingdom and the United States appoint an executive director, while
other member countries are represented by 20 executive directors.

• The President of the World Bank, Robert B. Zoellick, chairs meetings of the
Boards of Directors and is responsible for overall management of the Bank. By
tradition, the Bank president is a U.S. national and is nominated by the United
States, the Bank's largest shareholder. The President is selected by the Board of
Executive Directors for a five-year, renewable term.
• The Executive Directors make up the Boards of Directors of the World Bank.
They normally meet at least twice a week to oversee the Bank's business,
including approval of loans and guarantees, new policies, the administrative
budget, country assistance strategies and borrowing and financial decisions.

About 6,000 employees work at the World Bank's headquarters in Washington


D.C. and an additional 4,000 work in more than 100 offices in the World Bank's other
member countries.

16
The World Bank Tokyo Office Telephone: (03) 3597 6650
INTERNATIONAL BANK FOR RECONSTRUCTION AND DEVELOPMENT 10F, Fukoku Seimei Building Fax: (03) 3597 6695
INTERNATIONAL DEVELOPMENT ASSOCIATION 2-2-2, Uchisaiwai-Cho Cable: INTBAFRAD TOKYO

Sunday, December 2, 2018

Dear People,

I am attaching my emails to and from accountants. These


show massive fraud and corruption wherever you look.
None of the accountants, none of them, were willing to
admit their role in any of this fraud. The accountants did
not add up.

Sincerely,
Karen Hudes
Acting General Counsel, International Bank for
Reconstruction and Development
Overseer Mandate Trustee, Global Debt Facility, TVM-LSM-666

From: Karen Hudes


To: howard.isaac@international.gc.ca
Sent: Wed, Apr 28, 2010 9:08 am
Subject: Fwd: The World Bank's Internal Controls
Dear Howard,

Jules Muis is the World Bank's former Controller. Jules put me in touch with Ian Ball, who
heads the International Federation of Accountants, which develops standards for the
accounting profession. I met with IFAC several months ago.

Are you aware that the April 25, 2010 statement of James Flaherty at this year's spring
meetings is not available--instead last year's statement is posted.
http://web.worldbank.org/WBSITE/EXTERNAL/DEVCOMMEXT/0,,menuPK:60001657~
pagePK:64001141~piPK:64001176~theSitePK:277473,00.html

Is there any way to schedule a briefing session for the Board of Executive Directors so that
the World Bank's compliance issues can be dealt with properly? We cannot leave the heavy
lifting to the US institutions by themselves or it may backfire.
Sincerely,
Karen

-----Original Message-----
From: Karen Hudes
To: julesmuis@verizon.net; ianball@ifac.org
Cc: mmordasini@worldbank.org

1
Sent: Wed, Apr 28, 2010 9:00 am
Subject: Fwd: The World Bank's Internal Controls

Dear Jules and Ian,

KPMG's lawyer is trying to prevent its team auditing the World Bank's internal controls from
having to answer the specific issues raised by my case.

I am going to see if the Public Company Accounting Oversight Board will help. But PCAOB
is now under duress, because the US Supreme agreed to review the constitutionality of
PCAOB (the SEC appoints PCAOB's board members, rather than the US President)
http://www.webcpa.com/news/Supreme-Court-Questions-PCAOB-Constitutionality-
52678-1.html PCAOB has had many comments on previous audits carried out by KPMG.

If the US accounting oversight agency (PCAOB) cannot correct KPMG's external audit of the
World Bank's internal controls, the World Bank's Board may have to correct its corporate
governance problems without reference to the internal audit.

I am copying Mr. Michel Mordasini, the Swiss ED on the World Bank's Board, for his
information, because KPMG is a Swiss cooperative. KPMG international is supposed to
maintain uniform standards of work, and enhance the name of KPMG. I have also informed
advisers who work on governance issues in the German and Canadian Executive Directors'
offices of this problem.
Best,
Karen
_

-----Original Message-----
From: Karen Hudes
To: Tips@pcaobus.org
Sent: Wed, Apr 28, 2010 8:02 am
Subject: Fwd: The World Bank's Internal Controls

My calls to the tip line and to Mike Plotnick for the past week have not been returned. I am
coming to PCAOB this morning in order to speak with someone.

Sincerely,
Karen Hudes

-----Original Message-----
From: Karen Hudes
To: ugehlen@worldbank.org; cmacwilliam@worldbank.org
Sent: Tue, Apr 27, 2010 6:45 pm
Subject: Fwd: The World Bank's Internal Controls

For your information. KPMG's own control environment was called into question by a
UNDP whistleblower who reported corrupt practices in KPMG's Nairobi branch. [1]
2
[1] UNDP Whistleblower Details Comprehensive Wrongdoing in Somalia Projects, May
14, 2008, available at:
http://www.whistleblower.org/content/press_detail.cfm?press_id=1373

-----Original Message-----
From: Karen Hudes
To: dshontz@kpmg.com
Cc: Tips@pcaobus.org; ianball@ifac.org; karrt@sec.gov
Sent: Tue, Apr 27, 2010 6:12 pm
Subject: Re: The World Bank's Internal Controls

Dear Mr. Shontz,

My recollection of our first conversation was that I lamented the same failures in the
World Bank's Legal Department as GAO diagnosed in their 1999 report, and that by
default I was trying to do what I could to compensate for the resultant control lapses. I
do not recall your ever raising any misgivings about our conversations, either verbally or
in writing.

It is unusual that KPMG would not want the head of their audit to communicate with
me directly, but to go through counsel. This is especially unfortunate in light of
your hostile attacks out of context. I would like a written acknowledgment from the
head of KPMG's team that is evaluating the World Bank's internal controls that he
knows of my Sarbanes Oxley complaint and the issues I have raised about the IBRD's
compliance on the bond markets, specifically:

 my advice to the World Bank's Audit Committee about breaches in


the securities laws in the Philippines, inaccurate evaluation of
World Bank supervision of the Philippines Banking Sector Reform
Loan, and my comments on INT's defective report to the Audit
Committee
 the Legal Department's falsification of evidence in the World Bank
Administrative Tribunal, and the General Counsel's promotion to
ICSID of Nassib Ziade, the WBAT Executive Secretary, two weeks
after he admitted the tampered evidence
 the Legal Department's refusal to permit me to have external
arbitration of the validity of the Memorandum of Understanding, as
required by US appropriations legislation in 2005,
 the refusal of the President of the World Bank Administrative
Tribunal to allow me to continue my employment despite the
express breach of the Memorandum of Understanding, his active
arbitration practice with ICSID, and his exceeding his authority by
3
unilaterally imposing a stay, and thereby preventing other judges
on the Administrative Tribunal from considering falsified evidence
 the failure of the Office of Ethics and Business to sanction ethics
violations in the Legal and Health Departments and breach of the
World Bank's whistleblower protection policy by assigning EBC the
task of supervising a consultant to review my claims of
retaliation when EBC was precluded from further involvement in
my case
 the failure of the internal audit department to correct the inaccurate
evaluation on the Philippines Banking Sector Reform Loan
 that the Staff Association has stated that staff morale has been
impaired by the above internal control lapses
 that the World Bank refused to answer the letters from Senator
Lugar on my case and refused to cooperate with the GAO inquiry
 what the World Bank's Audit Committee has done with respect
to the above internal control lapses, other than appointing KPMG to
audit the World Bank's internal controls

Thank you.
Sincerely,
Karen Hudes
_

-----Original Message-----
From: Shontz, David B <dshontz@kpmg.com>
To: Karen Hudes
Sent: Tue, Apr 27, 2010 11:36 am
Subject: RE: The World Bank's Internal Controls

Ms. Hudes:

I have no idea why you would be telling an administrative assistant at KPMG that you
were once on the long list for General Counsel at the World Bank. In fact, you told me in
our first call that you were the Acting General Counsel for the World Bank even though
you had been fired (and I do not understand the logic of that either).

But to be clear, I have not suggested that you proceed along any lines whatsoever other
than that you not contact my clients, and instead direct communications though me,
their attorney (or through the Hotline or the Ombudsman). Any communications to me
should be in writing.

David B. Shontz, Associate General Counsel


Office of the General Counsel, KPMG LLP, 757 Third Avenue, New York, NY
10017
Cell: 914.714.5479; Cell2: 914.479.9092; Office: 212.909.5305; Office2:
914.630.4298 Fax: 212.954.5439

4
The information in this email is confidential and may be legally privileged. It is
intended solely for the addressee. Access to this email by anyone else is unauthorized. If
you are not the intended recipient, any disclosure, copying, distribution or any action
taken or omitted to be taken in reliance on it, is prohibited and may be unlawful.

From: Karen Hudes [mailto:Karen Hudes]


Sent: Tuesday, April 27, 2010 11:19 AM
To: Shontz, David B
Cc: Aalmofadhi@worldbank.org; Tips@pcaobus.org; heidi_crebo-
rediker@foreign.senate.gov; joe.onek@mail.house.gov;
Daniel.McGlinchey@mail.house.gov; Chris_Armstrong@finance-rep.senate.gov;
cory_gill@foreign.senate.gov; dgetter@crs.loc.gov; thomas_caballero@legal.senate.gov;
nbjorksten@crs.loc.gov; ianball@ifac.org; rtreffers@worldbank.org;
nmotapinto@worldbank.org; jhagan@worldbank.org; smoorehead@worldbank.org;
mmordasini@worldbank.org; mhasan@worldbank.org; swatson1@worldbank.org;
gmajnoni@worldbank.org
Subject: Re: The World Bank's Internal Controls

Dear Mr. Shontz,

Thank you for responding to unresolved corporate governance and ethics problems at
the World Bank which I raised in my email to you and to the Chairman of KPMG. I
followed up this morning with a fax to Mr. Timothy Flynn since I did not have his
correct email address and will direct a copy of this response to him as well. I
regret having to communicate complex issues to KPMG through your administrative
assistant (whom I simply asked to put me in touch with the individual at KPMG who is
directing KPMG's audit of the Bank's internal controls commissioned by the Bank's
Audit Committee. She must have misheard my statement to her that I was once on the
long list for the Bank's General Counsel).

The SEC, PCAOB, United States District Court for the District of Maryland, Bar
Counsel of the District of Columbia Court of Appeals, Government Accountability Office,
and US Congress are all involved in this protracted matter, and I think it is
counterproductive to proceed along the lines you suggest.

Sincerely,
Karen Hudes
_

-----Original Message-----
From: Shontz, David B <dshontz@kpmg.com>
To: Karen Hudes; tflynn@kpmg.com
Cc: Aalmofadhi@worldbank.org; Tips@pcaobus.org; heidi_crebo-
rediker@foreign.senate.gov; joe.onek@mail.house.gov;
Daniel.McGlinchey@mail.house.gov; Chris_Armstrong@finance-rep.senate.gov;
cory_gill@foreign.senate.gov; dgetter@crs.loc.gov; thomas_caballero@legal.senate.gov;
nbjorksten@crs.loc.gov; ianball@ifac.org; rtreffers@worldbank.org;

5
nmotapinto@worldbank.org; jhagan@worldbank.org; smoorehead@worldbank.org;
mmordasini@worldbank.org; mhasan@worldbank.org; swatson1@worldbank.org;
gmajnoni@worldbank.org
Sent: Tue, Apr 27, 2010 9:51 am
Subject: RE: The World Bank's Internal Controls
Ms. Hudes:

You apparently did not understand my prior email. I am not asking you to maintain
“secrecy” on this matter, or asking you to ignore what you believe to be your
professional and ethical obligations. You obviously may email or call whomever you
wish outside of KPMG about anything thing you wish to bring to their attention about
the World Bank or any other matter.

I am asking you to stop communicating with our staff (the latest two calls occurred
yesterday, including one where you apparently advised an administrative assistant that
you were the General Counsel of the World Bank and another where you apparently
advised one of our operations personnel that you had been fired from the World Bank).

As you point out, you are an attorney, and not an individual in this context. If you wish
to communicate further with KPMG LLP on this matter, please refer all communications
to me as the attorney for KPMG (except to the extent you choose instead to
communicate matters to the KPMG hotline, or for that matter, to the KPMG
Ombudsman). I will direct your communications to the appropriate individuals within
KPMG LLP.

Thank you for your attention to this email.

David B. Shontz, Associate General Counsel


Cell: 914.714.5479; Cell2: 914.479.9092; Office: 212.909.5305; Office2:
914.630.4298 Fax: 212.954.5439

From: Karen Hudes [mailto:Karen Hudes]


Sent: Monday, April 26, 2010 9:14 PM
To: Shontz, David B; tflynn@kpmg.com
Cc: Aalmofadhi@worldbank.org; Tips@pcaobus.org; heidi_crebo-
rediker@foreign.senate.gov; joe.onek@mail.house.gov;
Daniel.McGlinchey@mail.house.gov; Chris_Armstrong@finance-rep.senate.gov;
cory_gill@foreign.senate.gov; dgetter@crs.loc.gov; thomas_caballero@legal.senate.gov;
nbjorksten@crs.loc.gov; ianball@ifac.org; rtreffers@worldbank.org;
nmotapinto@worldbank.org; jhagan@worldbank.org; smoorehead@worldbank.org;
mmordasini@worldbank.org; mhasan@worldbank.org; swatson1@worldbank.org;
gmajnoni@worldbank.org
Subject: Re: The World Bank's Internal Controls

Dear Mr. Shontz,

I do indeed question your instructions and do not agree to comply with them. I am
not an individual in this context; I am an in-house lawyer who is obligated under the
6
Articles of Agreement of the International Bank for Reconstruction and
Development, US securities laws, and the DC bar code of professional conduct to bring
the IBRD into compliance on the capital market. KPMG has been entrusted with the
audit of a public international organization, and your demand of secrecy
also contravenes ethics codes of the accounting profession and KPMG's professed
values. Instead, I intend to forward your email to the chairs of committees of the Board
of Executive Directors of the World Bank, and to IBRD's oversight agencies, as I am
obligated to do and as the public interest requires.

Sincerely,
Karen Hudes
_
-----Original Message-----
From: Shontz, David B <dshontz@kpmg.com>
To: Karen Hudes
Sent: Mon, Apr 26, 2010 6:35 pm
Subject: RE: The World Bank's Internal Controls
Dear Ms. Hudes:

I’m sure you understand that we cannot comment to individuals on matters relating to
our clients.

The issues you raise have been directed to the appropriate individuals within KPMG.

To the extent you have any additional information, please submit that information only
to me, or to the Hotline that you have referred to in your past communications. I am the
attorney for KPMG on this matter, so, please do not contact anyone else at KPMG
regarding these matters (other than any Hotline communications you may wish to
engage in). I will direct any comments that you send to me to the appropriate parties.

Please let me know if you have any questions about my instructions above. Otherwise,
as an attorney yourself, I assume you will comply with them.

Regards,

David B. Shontz, Associate General Counsel

From: Karen Hudes [mailto:Karen Hudes]


Sent: Monday, April 26, 2010 6:09 PM
To: Shontz, David B
Subject: Fwd: The World Bank's Internal Controls

Dear Mr. Shontz,

What conclusion does KPMG draw about my Sarbanes Oxley complaint and the
IBRD's compliance issues?

7
As I mentioned to you, the SEC and the DC Court of Appeals are evaluating
IBRD's compliance on the capital
market after the Legal Department falsified evidence in the World Bank
Administrative Tribunal,
and the WBAT Executive Secretary was promoted two weeks after admitting the
tampered evidence.

GAO also has issues with the IBRD's failure to comply with 2005 appropriations
legislation
granting access of lawyers and accountants to external arbitration when making
protected disclosures to the
IBRD's Audit Committee and the World Bank's oversight committees in US Congress.

Please acknowledge receipt of this email and all five attachments.

Best,
Karen Hudes
_

-----Original Message-----
From: Karen Hudes
To: dshontz@kpmg.com
Sent: Mon, Apr 26, 2010 2:28 pm
Subject: Re: The World Bank's Internal Controls
Dear Mr. Shontz,

The attached summons in connection with the IBRD's violation of US securities


laws was served on the International Bank for Reconstruction and
Development on April 22, 2010. Other court filings are at clearviewconnects.com,
login 30795, password 72ef7b4. I have also complained to the District of Columbia
Court of Appeals about violations by IBRD's legal department of professional
ethics. Correspondence with the Assistant General Counsel of the SEC, Counsel to the
Inspector General of the SEC, and DC Bar Counsel on this matter is attached for your
information as well.

I also forward an email to the EC's representatives in Washington, in an attempt


to settle this matter prior to the recently concluded Spring meetings of the World Bank.
The chairs of the World Bank Board's Audit, Governance, and Ethics Committees, the
PCAOB, as well as
US Congressional Committees responsible for oversight of the World Bank, are also
apprised.

As soon as I have completed filing the Affidavit of Service with the US District
Court for the District of Maryland, I will give you a call.

Sincerely,
Karen Hudes

8
-----Original Message-----
From: Karen Hudes
To: info@capitolprocess.com
Sent: Wed, Apr 21, 2010 1:21 pm
Subject: Re: Job ID 10-037584
Mr. Green has refused to accept service of the summons and complaint. Please print out
the above pdf file and serve the World Bank at 1818 H St. NW. In case they refuse to
accept the summons,
just leave the papers near the individual who refuses to accept the papers and put a copy
of this email on top. http://openjurist.org/703/f2d/1305/novak-v-world-bank
Best,
Karen

-----Original Message-----
From: Green, Jeffrey T. <jgreen@Sidley.com>
To: Karen Hudes
Cc: Richardson, Rebecca
<rebecca.richardson@sidley.com>http://openjurist.org/703/f2d/1305/novak-v-world-
bank
Sent: Wed, Apr 21, 2010 12:15 pm
Subject: RE: Sarbanes-Oxley Complaint against the International Bank for
Reconstruction and Development
Dear Ms. Hudes –

Thank you for the e-mail below. I will await further information.

Please find attached a letter from me regarding the Amended Complaint.

Best, J.

Jeffrey T Green
Sidley Austin LLP
1501 K St NW
Washington, DC
20005-1401
202-736-8291 (desk)
jgreen@sidley.com

From: Karen Hudes


To: jgreen@Sidley.com
Cc: rebecca.richardson@sidley.com
Sent: Wed, Apr 21, 2010 2:15 pm
Subject: Re: Update on Possible Settlement of World Bank Sarbanes-Oxley Case
Dear Mr. Green,

9
Thank you for your email. If the Board is not prepared to resolve matters in time
for the Spring meetings, I would be very happy to meet you and/or Ms. Richardson in
the Hay Adams (16th & H) at 11:30 on Sunday morning.

Sincerely,
Karen Hudes

-----Original Message-----
From: Karen Hudes
To: vlassia.vassikeri@ec.europa.eu; despina.manos@ec.europa.eu;
geraldine.dufort@ec.europa.eu
Sent: Wed, Apr 21, 2010 1:59 pm
Subject: World Bank
Dear Geraldine, Vlassia and Despina,

I wanted to update the European Commission with regard to the issues discussed
during my meeting of July 1, 2009 with Vlassia and Despina. Since then, the World
Bank has refused to comply with an investigation of the Government Accountability
Office requested by the US Congess that was prompted by the attached disclosure to the
US Senate Committee on Foreign Relations. Senator Lugar is now demanding
reforms before approving a capital increase. The link to Senator Lugar's report is:
http://thecable.foreignpolicy.com/posts/2010/03/10/lugar_no_more_money_for_dev
elopment_banks_until_reform
I requested the Securities and Exchange Commission to remove the World Bank's
exemption from reporting and registration requirements, and complained about ethics
violations at the World Bank to Bar Counsel in the DC Court of Appeals. Last Friday the
Assistant General Counsel of the SEC requested Bar Counsel to inform him about the
ethics violations which I reported. (See attached letter to the DC Board on Professional
Responsibility). I have sued the International Bank for Reconstruction and
Development in Federal Court for the Southern District of Maryland for its violations
of US securities laws.

I have requested the Chairs of the World Bank Board Audit, Governance, and Ethics
Committees to suggest a counterpart to settle this lawsuit in order to protect the World
Bank from reputational risk. I hope that the EC will be able to assist in prompt
resolution of this matter.

Sincerely,
Karen

-----Original Message-----

10
From: Karen Hudes
To: SullivanMB@SEC.GOV; karrt@sec.gov
Cc: Tips@pcaobus.org; heidi_crebo-rediker@foreign.senate.gov;
joe.onek@mail.house.gov; Daniel.McGlinchey@mail.house.gov;
Chris_Armstrong@finance-rep.senate.gov; cory_gill@foreign.senate.gov;
dgetter@crs.loc.gov; thomas_caballero@legal.senate.gov; nbjorksten@crs.loc.gov;
EHontz@cipe.org; ianball@ifac.org
Sent: Fri, Apr 16, 2010 9:34 am
Subject: Governance Crisis at the World Bank
Dear Ms. Sullivan and Mr. Karr,

The International Bank for Reconstruction and Development has rebuffed the
efforts of Congress and the Government Accountability Office to resolve compliance
issues of the International Bank for Reconstruction and Development which I reported
to them (see attached). After IBRD refused to reinstate me, on April 9, 2010 I served the
summons and complaint on IBRD for the Sarbanes-Oxley case in the United States
District Court for the District of Maryland. On April 12, 2010 I met with Mr. Gene
Shipp, Jr., Bar Counsel of the District of Columbia, concerning ethics violations at
IBRD. I provided the documentation in my case to KPMG, external auditors
commissioned by the IBRD's Audit Committee, at www.clearviewconnects.com log-in
ID 30795, password 72ef7b4.

I would appreciate knowing what the SEC has decided to do with the issues I have
raised, what the grounds were for the decision, and what the time frame is going
forward.

Sincerely,
Karen Hudes
_

From: Karen Hudes [mailto:Karen Hudes]


Sent: Monday, April 19, 2010 9:50 AM
To: Green, Jeffrey T.
Subject: Re: Sarbanes-Oxley Complaint against the International Bank for
Reconstruction and Development

Dear Mr. Green,

I refer to our telephone conversation last week. The Board has been waiting for a
long time for the US to acknowledge the internal control deficiencies at the IBRD. I
would appreciate your cooperation in settling the Sarbanes-Oxley litigation at this time
in order to minimize the reputational risk to the IBRD.
Best,
Karen Hudes

11
----Original Message-----
From: Shontz, David B <dshontz@kpmg.com>
To: Karen Hudes
Sent: Mon, Apr 26, 2010 11:04 am
Subject: RE: The World Bank's Internal Controls April 25th 11:30 am Concorde Room
Hay Adams
Thank you.

David B. Shontz
---------- Forwarded message ----------
From: Karen Hudes <>
Date: Sun, Feb 12, 2012 at 8:44 AM
Subject: Re: Compliance of International Bank for Reconstruction and Development
To: lael.brainard@do.treas.gov

Dear Ms. Brainard,


Domestic and international oversight agencies of the World Bank community
including the securities markets, international organizations, academics, civil society
and legislatures are all assisting in bringing Mr. Zoellick to account, as per the attached.

Sincerely,
Karen Hudes
Law Offices of Karen Hudes

---------- Forwarded message ----------


From: Karen Hudes <>
Date: Sun, Feb 12, 2012 at 8:29 AM
Subject: Fwd: Compliance of International Bank for Reconstruction and Development
To: micah@adbusters.org

---------- Forwarded message ----------


From: Karen Hudes <>
Date: Fri, Feb 10, 2012 at 5:07 AM
Subject: Re: Compliance of International Bank for Reconstruction and Development
To: sharon.raj@fitchratings.com, rebecca.mirza@fitchratings.com
Dear Ms. Raj,
I spoke with Ms. Kerry-Ann Kirby, who referred me to you concerning the
compliance of the International Bank for Reconstruction and Development. KPMG's
audit of the IBRD's internal control over financial reporting, requested by the IBRD's
Audit Committee, did not comply with generally accepted audit principles, including
Standard No. 5 of the Public Company Accounting Oversight Board. This matter is also

12
before the International Organization of Supreme Audit Standards, the UK Parliament,
and the US Congress.

http://www.huffingtonpost.com/social/Karen_Hudes/china-financial-
reform_n_1191600_127701808.html

In the attached email, I have informed the head of staff of the Vice President of the
European Commission that I requested IBRD's Committee on Governance and
Administrative Matters of the Board of Executive Directors to bring the IBRD into
compliance at its upcoming meeting next week. The chronology of internal control
lapses was presented to the European Parliament's Committee on Budgetary Control in
testimony on May 25, 2011.

Please confirm receipt of this email and attachments. I would be happy to answer any
further questions.

Sincerely,
Karen Hudes
Law Offices of Karen Hudes

---------- Forwarded message ----------


From: Karen Hudes <>
Date: Thu, Feb 9, 2012 at 4:27 PM
Subject: Re: Rule of Law
To: henrik.hololei@ec.europa.eu

The Committee on Governance and Administrative Matters of the World Bank's


Board of Executive Directors is meeting next week to discuss this paper:

http://www-
wds.worldbank.org/external/default/WDSContentServer/WDSP/IB/2011/04/07/0003
56161_20110407011348/Rendered/PDF/607990CR0SU2011OFFICIAL0USE0ONLY19
1.pdf

From: karenhudes@hotmail.com
To: s-duff@dfid.gov.uk; ps-mason@dfid.gov.uk; wouter.biesterbos@minbuza.nl;
stefanie.teggemann@gtz.de; annika.calov@kfw.de; michael.krempin@gtz.de;
shaukat.hassan@acdi-cida.gc.ca; julia.thompson@acdi-cida.gc.ca;
infoausaid@ausaid.gov.au; sheena.graham@ausaid.gov.au
Subject: FW: Compliance of the IBRD
http://thecable.foreignpolicy.com/posts/2012/08/09/who_will_get_top_jobs_in_a_r

13
omney_administration#.UCPKU0cthsQ.email
Date: Fri, 10 Aug 2012 06:31:14 -0400

Over a year ago, I wrote the u4 governments on the attached problem of corruption. I
have asked the Chair of the Development Committee, Marek Belka, to put my case in the
US Court of Appeals into mediation. I am hoping that you will see to it that this
happens. Otherwise, there is a greater than 90% risk of a currency war. I have been
trying to end the cover-up at the World Bank for years.
Best,
Karen Hudes
Law Offices of Karen Hudes
begin_of_the_skype_highlighting FREE end_of_the_skype_highlighting

From: Karen Hudes


Sent: Thursday, June 30, 2011 10:56 AM
To: s-duff@dfid.gov.uk; ps-
mason@dfid.gov.uk; wouter.biesterbos@minbuza.nl; stefanie.teggemann@gtz.de; anni
ka.calov@kfw.de; Michael.Krempin@gtz.de; shaukat.hassan@acdi-
cida.gc.ca; julia.thompson@acdi-
cida.gc.ca; infoausaid@ausaid.gov.au; Sheena.Graham@ausaid.gov.au
Cc: Fylkesnes Gunvor Knag
Subject: Fwd: Compliance of the International Bank for Reconstruction and
Development on International Securities Markets

I am forwarding you my request that the u4 governments assist in efforts to strengthen


the dialogue with the US Congress on the functioning of the Bretton Woods institutions.
I am also forwarding you information on outstanding compliance issues of the
International Bank for Reconstruction and Development together with my background
paper for the European Parliament's Committee on Budgetary Control.

Over a year ago, I wrote the u4 governments on the attached problem of corruption.
I have asked the Chair of the Development Committee, Marek Belka, to put my case in
the US Court of Appeals into mediation. I am hoping that you will see to it that this
happens. Otherwise, there is a greater than 90% risk of a currency war. The US system
is too corrupt to cure itself, as you can see from the attached. I have been writing the
CFR to ask them to end the cover-up for years. The rest of the US press (and the world's
press for that matter) are refusing to report the story too.

Best,
Karen Hudes
Law Offices of Karen Hudes

From: karenhudes@hotmail.com
To: tjohnson@cfr.org
Subject: FW: Compliance of the IBRD
http://thecable.foreignpolicy.com/posts/2012/08/09/who_will_get_top_jobs_in_a_r
14
omney_administration#.UCPKU0cthsQ.email
Date: Fri, 10 Aug 2012 06:14:34 -0400

Dear Ms. Johnson,


I see that you are deputy editor at CFR and that you traveled to India to
report on a story about Muslims. The World Bank's members have been
supporting me in my efforts to fight this corruption every step of the way.
The whole issue is now in front of the World Bank's Development
Committee. I traveled to India in February: India is one of the countries
who has been helping me the most.
I am forwarding an email which sets out clearly where things stand.
Either we end the cover-up in the US first, or the rest of the world will do it
for us. CFR can help.
Best,KarenLaw Offices of Karen Hudeswww.kahudes.net
http://blogs.cfr.org/campaign-2012/2012/08/09/midday-update-zoellick-
to-lead-romney-defense-foreign-policy-transition/#comment-1849
Posted by Karen HudesAugust 10, 2012 at 5:49 am
Your comment is awaiting moderation.
Gayle Putrich has missed entirely what it meant when Romney picked Robert Zoellick as
his national security transition planning chief. Putrich thinks Zoellick’s “foreign policy
realism” is what makes Zoellick’s pick so controversial. The real issue is corruption. I am
a lawyer/economist who worked 20 years in the World Bank’s legal department. Zoellick
fired me in retaliation the month after I reported corruption at the World Bank to the
Senate Committee on Foreign Relations. The US Congress, UK Parliament and EU
Parliament have joined forces in a battle to fight the corruption that Zoellick promoted
at the World Bank. I should also add: the 3 credit rating agencies are looking on as this
saga unfolds. We will all suffer if the cover-up does not end.
I am suing the World Bank, its auditor KPMG, the lawyer hired to investigate my
whistleblower claims, and the Bank’s medical insurance administrator (who broke
medical confidentiality laws by disclosing my doctors’ names to the World Bank’s
medical department), in the DC Court of Appeals for the District of Columbia.

From: karenhudes@hotmail.com
To: john.hardy@usaexport.org; jmcpherson@naag.org; wijnand.marchal@minbuza.nl;
piotr.nowinakonopka@ep.europa.eu; info.eco@economie.fgov.be; j.hooper@frc.org.uk;
ianball@ifac.org; direction@cssf.lu; intosai@rechnungshof.gv.at; fcc@fsa.gov.uk;
clare.wells@europarl.europa.eu; elizabeth.noel@fco.gov.uk
Subject: FW: Compliance of the IBRD
http://thecable.foreignpolicy.com/posts/2012/08/09/who_will_get_top_jobs_in_a_r
omney_administration#.UCPKU0cthsQ.email
Date: Thu, 9 Aug 2012 10:43:12 -0400
Mr. Zoellick refused to end the corruption that is now squarely before the International
Bank for Reconstruction and Development's 3 credit rating agencies. The Romney
campaign's anxiety to distance themselves from Zoellick (as witnessed in this current
article) is not enough to solve the problem, though, of IBRD's compliance on the capital
markets after Zoellick's mismanagement there. Why would Romney want advice from
someone whose spectacular corruption just left so many insoluble problems in his

15
wake? See my previous comment at:
http://thecable.foreignpolicy.com/posts/2012/08/08/zoellick_pick_roils_romney_ca
mpaign#.UCM2-nrrsiM.email

From: karenhudes@hotmail.com
To: john.hardy@usaexport.org; jmcpherson@naag.org
CC: wijnand.marchal@minbuza.nl; piotr.nowinakonopka@ep.europa.eu;
info.eco@economie.fgov.be; j.hooper@frc.org.uk; ianball@ifac.org; direction@cssf.lu;
intosai@rechnungshof.gv.at; fcc@fsa.gov.uk; clare.wells@europarl.europa.eu;
elizabeth.noel@fco.gov.uk; tom.scholar@hmtreasury.gsi.gov.uk
Subject: Re: Compliance of the IBRD
Date: Thu, 9 Aug 2012 08:51:03 -0400

Dear Messrs. Hardy and McPherson,

Mr. Zoellick refused to end the corruption that is now squarely before the Board of
Governors of the IMF and World Bank. It is clear that the world will experience a
currency war unless there is an end to the lawlessness that I have so meticulously
documented these past ten years and which has brought the International Bank for
Reconstruction and Development out of compliance on the world's capital markets.

We seem to have a sequencing problem. I am leaving it in your capable hands what


happens first.

Best,
Karen
Law Offices of Karen Hudes

From: karenhudes@hotmail.com
To: jonathan_davidson@bennet.senate.gov; roger_low@bennet.senate.gov
Subject: FW:
http://thecable.foreignpolicy.com/posts/2012/08/08/zoellick_pick_roils_romney_ca
mpaign#.UCM2-nrrsiM.email
Date: Thu, 9 Aug 2012 08:35:14 -0400

From: Brian_Appel@bennet.senate.gov
To: karenhudes@hotmail.com
Subject: Automatic reply:
http://thecable.foreignpolicy.com/posts/2012/08/08/zoellick_pick_roils_romney_ca
mpaign#.UCM2-nrrsiM.email
Date: Thu, 9 Aug 2012 11:42:47 +0000

I will be out of the office from Wednesday, August 8 through Friday August 10.

I will check e-mail on a periodic basis.

16
From: karenhudes@hotmail.com
To: brian_appel@bennet.senate.gov
Subject:
http://thecable.foreignpolicy.com/posts/2012/08/08/zoellick_pick_roils_romney_ca
mpaign#.UCM2-nrrsiM.email
Date: Thu, 9 Aug 2012 07:42:44 -0400

Dear Brian,

I wanted to update Senator Bennet on what is happening on my lawsuit. I heard back


that the World Bank's Development Committee is following this closely, and are hoping
for the US to resolve this. I have contacted the Democratic Party to ask whether we
couldn't expose the cover-up and corruption now that Robert Zoellick is national
security adviser for the Romney campaign. It would be an elegant solution.

Here's my comment:

The US will have no national security if Robert Zoellick plays any role. Zoellick was not
offered a second term at the World Bank for good reason. The reason is that Zoellick lost
the Gentlemen's Agreement for the US to appoint the president of the World Bank
unilaterally. Fed up with corruption at the World Bank, on April 25, 2010 the 187
members rescinded the Gentlemen's Agreement for the US to name the World Bank
president http://www.imf.org/external/np/cm/2010/042510.htm, The US Congress
was also fed up with Zoellick's corruption. The requirements in US 2012
Appropriations legislation are in Section 7082 of H.R. 2055:
http://www.whistleblower.org/storage/documents/whistleblowerlanguageinHR2055.p
df Zoellick's last blooper: blowing up NATO. Our closest allies are now trying to help --
the UK Parliament has posted my
testimony:http://www.publications.parliament.uk/pa/cm201213/cmselect/cmintdev/w
ritev/402/contents.htm The press' coverage of this debacle is less than stellar.
http://www.forbes.com/sites/richardbehar/2012/06/27/world-bank-spins-out-of-
control-corruption-dysfunction-await-new-president/ (hit expand all comments
twice) Where does FP stand? www.kahudes.net

Best,
Karen

From: Appel, Brian (Bennet) [mailto:Brian_Appel@bennet.senate.gov]


Sent: Tuesday, July 24, 2012 3:35 PM
To: Karen Hudes
Subject: Follow up on Behalf of Jonathan Davidson

Karen:

Jonathan Davidson asked me to follow up with you regarding the World Bank. I would
be happy to talk with you about the issue at your convenience.

17
Brian

From: pwilson@glenecovapor.com
To: karenhudes@hotmail.com
Subject: RE: Karen Hudes v. Aetna Life Insurance Company, et al "Appellant/Petitioner
Brief Filed" (1:10-cv-01444-JEB)
Date: Wed, 8 Aug 2012 11:54:12 -0400

Good luck to ya.

From: Karen Hudes [mailto:karenhudes@hotmail.com]


Sent: Wednesday, August 08, 2012 11:00 AM
To: Jacek Kugler; g.smrkolj@uva.nl
Subject: Karen Hudes v. Aetna Life Insurance Company, et al "Appellant/Petitioner
Brief Filed" (1:10-cv-01444-JEB)

On Monday I filed my appeal in the Court of Appeals, DC Circuit.

-----Original Message-----
From: Karen Hudes
To: SullivanMB@SEC.GOV; karrt@sec.gov
Cc: Tips@pcaobus.org; heidi_crebo-rediker@foreign.senate.gov;
joe.onek@mail.house.gov; Daniel.McGlinchey@mail.house.gov;
Chris_Armstrong@finance-rep.senate.gov; cory_gill@foreign.senate.gov;
dgetter@crs.loc.gov; thomas_caballero@legal.senate.gov; nbjorksten@crs.loc.gov;
EHontz@cipe.org; ianball@ifac.org
Sent: Fri, Apr 16, 2010 9:34 am
Subject: Governance Crisis at the World Bank
Dear Ms. Sullivan and Mr. Karr,

The International Bank for Reconstruction and Development has rebuffed the
efforts of Congress and the Government Accountability Office to resolve compliance
issues of the International Bank for Reconstruction and Development which I reported
to them (see attached). After IBRD refused to reinstate me, on April 9, 2010 I served the
summons and complaint on IBRD for the Sarbanes-Oxley case in the United States
District Court for the District of Maryland. On April 12, 2010 I met with Mr. Gene
Shipp, Jr., Bar Counsel of the District of Columbia, concerning ethics violations at
IBRD. I provided the documentation in my case to KPMG, external auditors
commissioned by the IBRD's Audit Committee, at www.clearviewconnects.com log-in
ID 30795, password 72ef7b4.

18
I would appreciate knowing what the SEC has decided to do with the issues I have
raised, what the grounds were for the decision, and what the time frame is going
forward.

Sincerely,
Karen Hudes
_

From: Karen Hudes [mailto:Karen Hudes]


Sent: Monday, April 19, 2010 9:50 AM
To: Green, Jeffrey T.
Subject: Re: Sarbanes-Oxley Complaint against the International Bank for
Reconstruction and Development

Dear Mr. Green,

I refer to our telephone conversation last week. The Board has been waiting for a
long time for the US to acknowledge the internal control deficiencies at the IBRD. I
would appreciate your cooperation in settling the Sarbanes-Oxley litigation at this time
in order to minimize the reputational risk to the IBRD.
Best,
Karen Hudes

From: Karen Hudes [mailto:karenhudes@hotmail.com]


Sent: Wednesday, August 08, 2012 11:00 AM
To: Jacek Kugler; g.smrkolj@uva.nl
Subject: Karen Hudes v. Aetna Life Insurance Company, et al "Appellant/Petitioner
Brief Filed" (1:10-cv-01444-JEB)

On Monday I filed my appeal in the Court of Appeals, DC Circuit.

19
Karen has 3 files to share with you on SkyDrive. To view them, click the links below.

appeal117brief.pdf

appeal117addendum.pdf

appeal117appendix.pdf

Download all

Date: Mon, 6 Aug 2012 17:50:35 -0400


From: ecfnoticing@cadc.uscourts.gov
To: karenhudes@hotmail.com
Subject: KAREN HUDES v. INTERNATIONAL BANK FOR RECONSTRUCTION AND
DEVELOPMENT, KPMG LLP, AETNA LIFE INSURANCE COMPANY, AND MARK E.
SCHREIBER, US Court of Appeals Case Number 11-7109

***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United


States policy permits attorneys of record and parties in a case (including
pro se litigants) to receive one free electronic copy of all documents filed
electronically, if receipt is required by law or directed by the filer. PACER
access fees apply to all other users. To avoid later charges, download a copy
of each document during this first viewing.

United States Court of Appeals for District of Columbia Circuit

Amended 08/06/2012 17:50:35: Notice of Docket Activity

The following transaction was entered on 08/06/2012 at 5:04:56 PM EDT and filed on
08/06/2012

Case Name: Karen Hudes v. Aetna Life Insurance Company, et al


Case Number: 11-7109
Document(s): Document(s)

Docket Text:
APPELLANT BRIEF [1387774] filed by Karen Hudes [Service Date: 08/06/2012 ]
Length of Brief: 6959 words. [11-7109] (Hudes, Karen)

20
Notice will be electronically mailed to:

Bryan D. Bolton: bbolton@fblaw.com, mreed@fblaw.com, crobertson@fblaw.com


Mr. Michael Patrick
Cunningham: mcunningham@fblaw.com, mreed@fblaw.com, crobertson@fblaw.com
Marc B. Dorfman: mdorfman@foley.com, cursin@foley.com
Mr. Jeffrey T.
Green: jgreen@sidley.com, kblackstone@sidley.com, desprit.smith@sidley.com, hingra
m@sidley.com
Ms. Karen Hudes: karenhudes@hotmail.com
Mr. David S. Petron: dpetron@sidley.com
Stanley James Reed: sjreed@lerchearly.com

From: karenhudes@hotmail.com
To: jtuohey@globe.com
Subject: Re: UK Preserves Rule of Law -- Saves Transatlantic Alliance
Date: Sun, 15 Jul 2012 10:34:32 -0400

I am a Yale Law school-educated lawyer and economist who worked in the World
Bank's legal department for 20 years. In 2007 Robert Zoellick, then President of the
World Bank, fired me in retaliation after I reported a governance crisis at the World
Bank to the Senate Committee on Foreign Relations.
www.kahudes.net

http://www.forbes.com/sites/richardbehar/2012/06/27/world-bank-spins-out-of-
control-corruption-dysfunction-await-new-president/

Mr. Behar has left out how the Bush Administration attempted to prevent Paul
Wolfowitz’ resignation from the presidency of the World Bank by threatening to reveal
sensitive information about the Executive Directors on the Board. Herman Wijffels, the
Dutch Executive Director at the World Bank, led the Board’s inquiry into illegal pay
raises to Wolfowitz’ romantic interest, Shaha Riza. Riza, who worked at the World Bank
prior to Wolfowitz’ appointment, received a 35% raise just months after Wolfowitz
assumed the presidency of the World Bank.

Wijffels reported, “There was digging into my past in a shocking manner. In my case
there was nothing to find. Very clear efforts to disqualify my fellow Directors led to
consternation.” I am a Yale Law educated lawyer and University of Amsterdam educated
economist who worked in the World Bank’s legal department for 20 years. I reported to
the Senate Committee on Foreign Relations, then chaired by Vice President Joe Biden,
the risks to the reputation of the United States. Robert Zoellick fired me in retaliation in
2007.
I also reported the corrupt take-over of Philippines National Bank, the second largest
bank in the Philippines. Lucio Tan, a crony of then-President of the Philippines Joseph
Estrada, acquired stock owned by government employees in Philippines National Bank
in violation of Philippines securities laws. Tan owned Philippines Airlines, in default on

21
its loans from PNB. The government of the Philippines loaned $493 million to PNB after
PNB’s depositors made heavy withdrawals. $200 million from a World Bank loan and
$200 million from a Japanese loan was cancelled. Estrada was ultimately impeached,
and in 2007 an anti-corruption court in the Philippines required Estrada to refund graft
he had plundered.
The World Bank’s Country Director in the Philippines reassigned me when I asked him
to warn the Philippines’ government that the World Bank could not disburse its loan.
The World Bank’s Internal Audit Department refused to correct the satisfactory
evaluation of the World Bank’s supervision performance or the flawed report of the
Institutional Integrity Department to the Audit Committee of the Board of Executive
Directors.
The Audit Committee requested an inquiry into the Institutional Integrity Department.
The Paul Volcker Panel investigation into the Institutional Integrity Department was
discredited after “deliberate and substantial interference with this supposedly
independent commission” came to light.
http://www.commondreams.org/newswire/2010/04/06-3
The World Bank stonewalled four letters from Congress into my disclosures. The World
Bank also stonewalled a Government Accountability Office inquiry into transparency at
the World Bank requested by Senators Richard Lugar, Evan Bayh, and Patrick Leahy.
http://citizenoversight.com/pdf/blwb.pdf I warned the Joint Economic Committee an
accurate political science stakeholder analysis was predicting that without rule of law at
the World Bank the United States would lose the Gentlemen’s Agreement for the US to
appoint the president of the World Bank The analysis uses modern game theory to
simulate a bargaining process among stakeholders and is 90% accurate.
The 187 member countries of the World Bank rescinded the 66 year old Gentlemen’s
Agreement in 2010. http://www.imf.org/external/np/cm/2010/042510.htm The World
Bank’s Board of Executive Directors selected Dr. Kim as the World Bank’s president
from a field of three nominees, including Nigeria’s Finance Minister, Ngozi Okonjo
Iweala and Colombia’s former Finance Minister, Jose Antonio Ocampo.
The US Congress is requiring results that eliminate retaliation against whistleblowers in
the 2012 appropriations legislation for the World Bank capital increase. You can read
more about my whistleblower retaliation case in the US Court of Appeals, DC Circuit at
www.kahudes.net

https://twitter.com/KarenHudes,

https://www.facebook.com/karen.hudes.10/

On Tuesdays at 7:00 pm EST http://dctv.org/Live

22
https://www.youtube.com/user/KarenHudes

www.kahudes.net
interviews: https://s3.amazonaws.com/khudes/Bibliography1.pdf

23
MEMORANDUM
TO: Board of Executive Directors
FROM: Karen Hudes

RE: Mandate of the Board of Executive Directors

DATE: September 1, 2009

The Articles of Agreement of the International Bank for Reconstruction and


Development (IBRD) confer broad powers to the Executive Directors, including under
Article IX(a) decisions on questions of interpretation of the Articles. All of the powers of
the IBRD are vested in the Board of Governors, and except for certain reserved powers
regarding membership and appeals from the Board's interpretations of the Articles of
Agreement, these powers may be delegated to the Executive Directors. Section 4(a) of
Article V provides that "[t]he Executive Directors shall be responsible for the conduct of
the general operations of the Bank, and for this purpose, shall exercise all the powers
delegated to them by the Board of Governors."

The powers of the President to conduct the ordinary business of IBRD under Article V,
Section 5(b) are "under the direction of the Executive Directors." "Subject to the general
control of the Executive Directors, [the President] shall be responsible for the
organization, appointment and dismissal of the officers and staff."

On June 4, 1947, the Executive Directors accepted in a Memorandum with Regard to


Organization and Loan Procedure that "[t]he Executive Directors are responsible for the
decision of all matters of policy in connection with the operations of the Bank, including
the approval of loans," and "[tjhe Management is responsible for developing
recommendations in all matters of policy requiring decision by the Executive Directors."
"Whenever, in connection with the operations of the Bank, decision of a question of
policy becomes necessary, the President will submit such question to the Executive
Directors with the recommendation of the management as to the action to be taken..."

Under Article IX of the Articles of Agreement, Executive Directors have authority to


interpret the Articles consistent with the rights conferred to Executive Directors for the
exercise of general control over IBRD's organization, appointment and dismissal of
officers and staff. There is no obligation under the Articles of Agreement for Executive
Directors to wait for the President to recommend specific actions to be taken. Canada's
Review of Internal Governance Conclusions and Proposals has noted that the Board
remains accountable under IBRD's Articles of Agreement for delegated tasks.

It is for the Executive Directors to determine if they are now obligated to avail of the full
range of powers in the original mandate of the Executive Directors contained in the
Articles of Agreement.
https://twitter.com/KarenHudes,

https://www.facebook.com/karen.hudes.10/

On Tuesdays at 7:00 pm EST http://dctv.org/Live

https://www.youtube.com/user/KarenHudes

www.kahudes.net
interviews: https://s3.amazonaws.com/khudes/Bibliography1.pdf
https://twitter.com/KarenHudes,

https://www.facebook.com/karen.hudes.10/

On Tuesdays at 7:00 pm EST http://dctv.org/Live

https://www.youtube.com/user/KarenHudes

www.kahudes.net
interviews: https://s3.amazonaws.com/khudes/Bibliography1.pdf

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