Kathleen Hamann and Sarah Remes Co-author Article for Global Investigations Review: Building Robust Compliance Programs Under the MDB General Principles for Business Integrity Programs
Pierce Atwood litigation and corporate compliance attorneys Kate Hamann and Sarah Remes co-authored an article recently published by Global Investigations Review, where they discussed the evolution of guidance that was launched nearly two decades ago as a program to combat bribery, but in recent years has expanded beyond corruption and into other areas of economic crime, including tax evasion, money laundering, and trade compliance.
In December 2025, (International Anti-corruption Day), 16 years after issuing the original Good Practice Guidance, the World Bank Group as launched the revised World Bank Group Integrity Compliance Guidelines (Integrity Guidelines), comprising 28 principles spanning eight pages, building on the guidance that had been issued since the original guidelines, and raising the bar on what is required.
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Kathleen Hamann is an internationally recognized authority in the field of white-collar enforcement and compliance matters. Drawing on her nearly 20 years of service to the federal government, in roles at the US Department of Justice and Department of State, Kathleen helps clients navigate the complexities of U.S. and transnational criminal liability and multijurisdictional government investigations.
Sarah Remes represents clients in complex commercial litigation, including class actions, construction, and employment-related disputes. She also represents clients in governmental and internal investigations and enforcement actions by the multilateral development banks. With particular experience with anti-money laundering and trade sanctions, Sarah assists companies across a range of industries in developing and evaluating their compliance programs.
This article was first published on Global Investigations Review in February 2026; for further in-depth analysis, please visit GIR The Guide to Multilateral Development Bank Investigations - Edition 2