68 Am. U. L. Rev. 1373 (2019).

* Mr. Swan is Counsel (Sanctions) in the World Bank Office of Suspension and Debarment and a former law clerk to the Honorable Jimmie V. Reyna, Circuit Judge, United States Court of Appeals for the Federal Circuit.

** Mr. Pham is a third-year law student at the George Washington University Law School.

The Authors would like to thank Nathaniel E. Castellano, Karen Thornton, Eric Valle, and the editors of the American University Law Review for their time and helpful comments on this Area Summary.  The findings, interpretations, and conclusions expressed herein are those of the authors and do not necessarily reflect the views of the World Bank Group, its board of directors, or the governments they represent.