Accused charged with bribery of foreign public officials sought production of investigative records from the World Bank’s Integrity Vice Presidency in support of a Garofoli challenge to wiretap authorizations.
The World Bank asserted immunity as an international organization and refused to produce additional materials.
The court held that by initiating and actively assisting the Canadian criminal investigation, the organization had impliedly waived immunity and must accept the procedural burdens of a criminal prosecution.
The applicants established likely relevance under the first stage of the O’Connor framework.
Production was ordered for certain investigative materials for judicial review.
