Current Developments in Monetary and Financial Law, Vol. 2
Back Matter

Back Matter

Author(s):
International Monetary Fund
Published Date:
October 2003
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    Appendix

    Appendix Code of Good Practices on Transparency in Monetary and Financial Policies: Declaration of Principles

    Introduction

    In the context of strengthening the architecture of the international monetary and financial system, the Interim Committee in its April and October 1998 Communiqués called on the Fund to develop a code of transparency practices for monetary and financial policies, in cooperation with appropriate institutions. The Fund, working together with the Bank for International Settlements, and in consultation with a representative group of central banks, financial agencies, other relevant international and regional organizations,1 and selected academic experts, has developed a Code of Good Practices on Transparency in Monetary and Financial Policies. The Code parallels the Code of Good Practices on Fiscal Transparency developed by the Fund and endorsed by the Interim Committee in April 1998.

    The Code of Good Practices on Transparency in Monetary and Financial Policies identifies desirable transparency practices for central banks in their conduct of monetary policy and for central banks and other financial agencies in their conduct of financial policies. The definitions of “central bank,” “financial agencies,” “financial policies,” and “government” as used in this Code are given in the attached Annex.

    For purposes of the Code, transparency refers to an environment in which the objectives of policy, its legal, institutional, and economic framework, policy decisions and their rationale, data and information related to monetary and financial policies, and the terms of agencies' accountability, are provided to the public on an understandable, accessible, and timely basis. Thus, the transparency practices listed in the Code focus on (1) clarity of roles, responsibilities, and objectives of central banks and financial agencies; (2) the processes for formulating and reporting of monetary policy decisions by the central bank and of financial policies by financial agencies; (3) public availability of information on monetary and financial policies; and (4) accountability and assurances of integrity by the central bank and financial agencies.

    The case for transparency of monetary and financial policies is based on two main premises. First, the effectiveness of monetary and financial policies can be strengthened if the goals and instruments of policy are known to the public and if the authorities can make a credible commitment to meeting them. In making available more information about monetary and financial policies, good transparency practices promote the potential efficiency of markets. Second, good governance calls for central banks and financial agencies to be accountable, particularly where the monetary and financial authorities are granted a high degree of autonomy. In cases when conflicts might arise between or within government units (e.g., if the central bank or a financial agency acts as both owner and financial supervisor of a financial institution or if the responsibilities for monetary and foreign exchange policy are shared), transparency in the mandate and clear rules and procedures in the operations of the agencies can help in their resolution, strengthen governance, and facilitate policy consistency.

    In making the objectives of monetary policy public, the central bank enhances the public’s understanding of what it is seeking to achieve, and provides a context for articulating its own policy choices, thereby contributing to the effectiveness of monetary policy. Further, by providing the private sector with a clear description of the considerations guiding monetary policy decisions, transparency about the policy process makes the monetary policy transmission mechanism generally more effective, in part by ensuring that market expectations can be formed more efficiently. By providing the public with adequate information about its activities, the central bank can establish a mechanism for strengthening its credibility by matching its actions to its public statements.

    Transparency by financial agencies, particularly in clarifying their objectives, should also contribute to policy effectiveness by enabling financial market participants to better assess the context of financial policies, thereby reducing uncertainty in the decision making of market participants. Moreover, by enabling market participants and the general public to understand and evaluate financial policies, transparency is likely to be conducive to good policymaking. This can help to promote financial as well as systemic stability. Transparent descriptions of the policy formulation process provide the public with an understanding of the rules of the game. The release of adequate information to the public on the activities of financial agencies provides an additional mechanism for enhancing the credibility of their actions. There may also be circumstances when public accountability of decisions by financial agencies can reduce the potential for moral hazard.

    The benefits for countries adopting good transparency practices in monetary and financial policies have to be weighed against the potential costs. In situations where increased transparency in monetary and financial policies could endanger the effectiveness of policies, or be potentially harmful to market stability or the legitimate interests of supervised and other entities, it may be appropriate to limit the extent of such transparency. Limiting transparency in selected areas needs to be seen, however, in the context of a generally transparent environment.

    In the case of monetary policy, the rationale for limiting some types of disclosure arises because it could adversely affect the decision-making process and the effectiveness of policies. Similarly, exchange rate policy considerations, notably, but not exclusively, in countries with fixed exchange rate regimes, may provide justification for limiting certain disclosure practices. For example, extensive disclosure requirements about internal policy discussion on money and exchange market operations might disrupt markets, constrain the free flow of discussion by policymakers, or prevent the adoption of contingency plans. Thus, it might be inappropriate for central banks to disclose internal deliberations and documentation, and there are circumstances in which it would not be appropriate for central banks to disclose their near-term monetary and exchange rate policy implementation tactics and provide detailed information on foreign exchange operations. Similarly, there may be good reasons for the central bank (and financial agencies) not to make public their contingency plans, including possible emergency lending.

    Additional concerns could be posed by some aspects of the transparency of financial policies. Moral hazard, market discipline, and financial market stability considerations may justify limiting both the content and timing of the disclosure of some corrective actions and emergency lending decisions, and information pertaining to market and firm-specific conditions. In order to maintain access to sensitive information from market participants, there is also a need to safeguard the confidentiality and privacy of information on individual firms (commonly referred to as “commercial confidentiality”). Similarly, it may be inappropriate for financial authorities to make public their supervisory deliberations and enforcement actions related to individual financial institutions, markets, and individuals.

    Transparency practices differ not only in substance, but also in form. With regard to informing the public about monetary and financial institutions and their policies, an important issue concerns the modalities that these public disclosures should take. In particular with regard to monetary policy, should transparency practices have a legislative basis in a central bank law, or be based in other legislation or regulation, or be adopted through other means? The Code takes a pragmatic approach to this issue and recognizes that a variety of arrangements can lead to good transparency practices. On matters pertaining to the roles, responsibilities, and objectives of central banks (and for principal financial regulatory agencies), it recommends that key features be specified in the authorizing legislation (e.g., a central bank law). Specifying some of these practices in legislation gives them particular prominence and avoids ad hoc and frequent changes to these important aspects of the operations of central banks and relevant financial agencies. Information about other transparency aspects, such as how policy is formulated and implemented and the provision of information, can be presented in a more flexible manner. However, it is important that such information be readily accessible, so that the public can with reasonable effort obtain and assimilate the information.

    In the context of good governance and accountability, as well as the promotion of efficient markets, reference to the public in this code should ideally encompass all interested individuals and institutions. In some cases, particularly for financial policies, it may be expedient for the purposes of administering or implementing certain regulations and policies to define the concept of the public more narrowly to refer only to those individuals and institutions that are most directly affected by the regulations and policies in question.

    The focus of the Code is on transparency. While good transparency practices for the formulation and reporting of monetary and financial policies help to contribute to the adoption of sound policies, the Code is not designed to offer judgments on the appropriateness or desirability of specific monetary or financial policies or frameworks that countries should adopt. Transparency is not an end in itself, nor is transparency a substitute for pursuing sound policies; rather, transparency and sound policies are better seen as complements. In the realm of financial policies, there are complements to this code that go beyond transparency to promote good policies, notably the Core Principles for Effective Banking Supervision formulated by the Basel Committee for Banking Supervision, the Objectives and Principles of Securities Regulation formulated by the International Organization of Securities Commissions (IOSCO), and standards being developed by the Committee on Payment and Settlement Systems (CPSS), the International Association of Insurance Supervisors (IAIS), and the International Accounting Standards Committee (IASC). As these and other financial sector groupings develop and make significant adjustments in their principles and standards as they relate to transparency practices for financial agencies (e.g., in data dissemination requirements for financial agencies), this Code may have to be adjusted accordingly.

    The Code is directed at the transparency requirements of central banks and financial agencies, not at the transparency procedures relating to firms and individual institutions. However, the benefits of transparency for monetary and financial policies may be fostered by appropriate policies to promote transparency for markets in general, for the institutions that are being supervised, and for self-regulatory organizations.

    Monetary and financial policies are interrelated and often mutually reinforcing, with the health of the financial system affecting the conduct of monetary policy and vice versa. However, the institutional arrangements for these two types of policies differ considerably, particularly with regard to their roles, responsibilities, and objectives and their policy formulation and implementation processes. To take account of this, the Code is separated into two parts: good transparency practices for monetary policy by central banks and good transparency practices for financial policies by financial agencies. The basic elements of transparency for both policies are, however, similar. It should be recognized that not all transparency practices are equally applicable to all financial agencies, and the transparency objectives among different financial sectors vary. For some, the emphasis is on market efficiency considerations, for others the focus is on market and systemic stability, while for others the principal consideration is client-asset protection.

    The operation of a country’s payment system affects the conduct of monetary policies and the functioning of the financial system, and the design of payment systems has implications for systemic stability. The institutional structures of the payment system, however, are often significantly more complex than for monetary and other financial policies, and differ considerably across countries. In many instances, the operation of a country’s payment system is split between the public and private sectors, including self-regulatory bodies. Nevertheless, most of the transparency practices listed in the Code for financial agencies are applicable for the roles and functions of central banks or other relevant public agencies exercising responsibility for overseeing the nation’s payment systems. The coverage of transparency practices for financial policies in the Code includes those for the operation of systemically important components of the nation’s payment system, and, where appropriate, makes allowance for the special nature of the payment system’s operations (see section 5.3 of the Code).

    The Code is of sufficient breadth to span and be applied to a wide range of monetary and financial frameworks, and thus to the full range of the Fund membership. Elements of the Code are drawn from a review of good transparency practices used in a number of countries and discussed in the professional literature. The Code thus represents a distillation of concepts and practices that are already in use and for which there is a record of experience. The manner in which transparency is applied and achieved, however, may differ, reflecting different institutional arrangements with respect to monetary and financial policies and legal traditions. The good transparency practices contained in the Code will, therefore, have to be implemented flexibly and over time to take account of a country’s particular circumstances. A number of Fund members currently lack sufficient resources and the institutional capacity to implement all of the good transparency practices listed in the Code. These practices are included in the Code in the anticipation that countries would aspire over time to introduce such good practices.

    Good Transparency Practices for Monetary Policy by Central Banks

    I. Clarity of Roles, Responsibilities, and Objectives of Central Banks for Monetary Policy

    1.1 The ultimate objective(s) and institutional framework of monetary policy should be clearly defined in relevant legislation or regulation, including, where appropriate, a central bank law.

    1.1.1 The ultimate objective(s) of monetary policy should be specified in legislation and publicly disclosed and explained.

    1.1.2 The responsibilities of the central bank should be specified in legislation.

    1.1.3 The legislation establishing the central bank should specify that the central bank has the authority to utilize monetary policy instruments to attain the policy objective(s).

    1.1.4 Institutional responsibility for foreign exchange policy should be publicly disclosed.

    1.1.5 The broad modalities of accountability for the conduct of monetary policy and for any other responsibilities assigned to the central bank should be specified in legislation.

    1.1.6 If, in exceptional circumstances, the government has the authority to override central bank policy decisions, the conditions under which this authority may be invoked and the manner in which it is publicly disclosed should be specified in legislation.

    1.1.7 The procedures for appointment, terms of office, and any general criteria for removal of the heads and members of the governing body of the central bank should be specified in legislation.

    1.2 The institutional relationship between monetary and fiscal operations should be clearly defined.2

    1.2.1 If credits, advances, or overdrafts to the government by the central bank are permitted, the conditions when they are permitted, and any limits thereof, should be publicly disclosed.

    1.2.2 The amounts and terms of credits, advances, or overdrafts to the government by the central bank and those of deposits of the government with the central bank should be publicly disclosed.

    1.2.3 The procedures for direct central bank participation in the primary markets for government securities, where permitted, and in the secondary markets should be publicly disclosed.

    1.2.4 Central bank involvement in the rest of the economy (e.g., through equity ownership, membership on governing boards, procurement, or provision of services for fee) should be conducted in an open and public manner on the basis of clear principles and procedures.

    1.2.5 The manner in which central bank profits are allocated and how capital is maintained should be publicly disclosed.

    1.3 Agency roles performed by the central bank on behalf of the government should be clearly defined.

    1.3.1 Responsibilities, if any, of the central bank in (i) the management of domestic and external public debt and foreign exchange reserves, (ii) as banker to the government, (iii) as fiscal agent of the government, and (iv) as advisor on economic and financial policies and in the field of international cooperation should be publicly disclosed.

    1.3.2 The allocation of responsibilities among the central bank, the ministry of finance, or a separate public agency,3 for the primary debt issues, secondary market arrangements, depository facilities, and clearing and settlement arrangements for trade in government securities should be publicly disclosed.

    II. Open Process for Formulating and Reporting Monetary Policy Decisions

    2.1 The framework, instruments, and any targets that are used to pursue the objectives of monetary policy should be publicly disclosed and explained.

    2.1.1 The procedures and practices governing monetary policy instruments and operations should be publicly disclosed and explained.

    2.1.2 The rules and procedures for the central bank’s relationships and transactions with counter parties in its monetary operations and in the markets where it operates should be publicly disclosed.

    2.2 Where a permanent monetary policymaking body meets to assess underlying economic developments, monitor progress toward achieving its monetary policy objective(s), and formulate policy for the period ahead, information on the composition, structure, and functions of that body should be publicly disclosed.

    2.2.1 If the policymaking body has regularly scheduled meetings to assess underlying economic developments, monitor progress toward achieving its monetary policy objective(s), and formulate policy for the period ahead, the advance meeting schedule should be publicly disclosed.

    2.3 Changes in the setting of monetary policy instruments (other than fine-tuning measures) should be publicly announced and explained in a timely manner.

    2.3.1 The central bank should publicly disclose, with a preannounced maximum delay, the main considerations underlying its monetary policy decisions.

    2.4 The central bank should issue periodic public statements on progress toward achieving its monetary policy objective(s) as well as prospects for achieving them. The arrangements could differ depending on the monetary policy framework, including the exchange rate regime.

    2.4.1 The central bank should periodically present its monetary policy objectives to the public, specifying, inter alia, their rationale, quantitative targets and instruments where applicable, and the key underlying assumptions.

    2.4.2 The central bank should present to the public on a specified schedule a report on the evolving macroeconomic situation, and their implications for its monetary policy objective(s).

    2.5 For proposed substantive technical changes to the structure of monetary regulations, there should be a presumption in favor of public consultations, within an appropriate period.

    2.6 The regulations on data reporting by financial institutions to the central bank for monetary policy purposes should be publicly disclosed.

    III. Public Availability of Information on Monetary Policy

    3.1 Presentations and releases of central bank data should meet the standards related to coverage, periodicity, timeliness of data, and access by the public that are consistent with the International Monetary Fund’s data dissemination standards.

    3.2 The central bank should publicly disclose its balance sheet on a preannounced schedule and, after a predetermined interval, publicly disclose selected information on its aggregate market transactions.

    3.2.1 Summary central bank balance sheets should be publicly disclosed on a frequent and preannounced schedule. Detailed central bank balance sheets prepared according to appropriate and publicly documented accounting standards should be publicly disclosed at least annually by the central bank.

    3.2.2 Information on the central bank’s monetary operations, including aggregate amounts and terms of refinance or other facilities (subject to the maintenance of commercial confidentiality) should be publicly disclosed on a preannounced schedule.

    3.2.3 Consistent with confidentiality and privacy of information on individual firms, aggregate information on emergency financial support by the central bank should be publicly disclosed through an appropriate central bank statement when such disclosure will not be disruptive to financial stability.

    3.2.4 Information about the country’s foreign exchange reserve assets, liabilities, and commitments by the monetary authorities should be publicly disclosed on a preannounced schedule, consistent with the International Monetary Fund’s Data Dissemination Standards.

    3.3 The central bank should establish and maintain public information services.

    3.3.1 The central bank should have a publications program, including an Annual Report.

    3.3.2 Senior central bank officials should be ready to explain their institution’s objective(s) and performance to the public, and have a presumption in favor of releasing the text of their statements to the public.

    3.4 Texts of regulations issued by the central bank should be readily available to the public.

    IV. Accountability and Assurances of Integrity by the Central Bank

    4.1 Officials of the central bank should be available to appear before a designated public authority to report on the conduct of monetary policy, explain the policy objective(s) of their institution, describe their performance in achieving their objective(s), and, as appropriate, exchange views on the state of the economy and the financial system.

    4.2 The central bank should publicly disclose audited financial statements of its operations on a preannounced schedule.

    4.2.1 The financial statements should be audited by an independent auditor. Information on accounting policies and any qualification to the statements should be an integral part of the publicly disclosed financial statements.

    4.2.2 Internal governance procedures necessary to ensure the integrity of operations, including internal audit arrangements, should be publicly disclosed.

    4.3 Information on the expenses and revenues in operating the central bank should be publicly disclosed annually.

    4.4 Standards for the conduct of personal financial affairs of officials and staff of the central bank and rules to prevent exploitation of conflicts of interest, including any general fiduciary obligation, should be publicly disclosed.

    4.4.1 Information about legal protections for officials and staff of the central bank in the conduct of their official duties should be publicly disclosed.

    Good Transparency Practices for Financial Policies by Financial Agencies

    V. Clarity of Roles, Responsibilities, and Objectives of Financial Agencies Responsible for Financial Policies4

    5.1 The broad objective(s) and institutional framework of financial agencies should be clearly defined, preferably in relevant legislation or regulation.

    5.1.1 The broad objective(s) of financial agencies should be publicly disclosed and explained.

    5.1.2 The responsibilities of the financial agencies and the authority to conduct financial policies should be publicly disclosed.

    5.1.3 Where applicable, the broad modalities of accountability for financial agencies should be publicly disclosed.

    5.1.4 Where applicable, the procedures for appointment, terms of office, and any general criteria for removal of the heads and members of the governing bodies of financial agencies should be publicly disclosed.

    5.2 The relationship between financial agencies should be publicly disclosed.

    5.3 The role of oversight agencies with regard to payment systems should be publicly disclosed.

    5.3.1 The agencies overseeing the payment system should promote the timely public disclosure of general policy principles (including risk management policies) that affect the robustness of systemically important payment systems.

    5.4 Where financial agencies have oversight responsibilities for self-regulatory organizations (e.g., payment systems), the relationship between them should be publicly disclosed.

    5.5 Where self-regulatory organizations are authorized to perform part of the regulatory and supervisory process, they should be guided by the same good transparency practices specified for financial agencies.

    VI. Open Process for Formulating and Reporting of Financial Policies

    6.1 The conduct of policies by financial agencies should be transparent, compatible with confidentiality considerations and the need to preserve the effectiveness of actions by regulatory and oversight agencies.

    6.1.1 The regulatory framework and operating procedures governing the conduct of financial policies should be publicly disclosed and explained.

    6.1.2 The regulations for financial reporting by financial institutions to financial agencies should be publicly disclosed.

    6.1.3 The regulations for the operation of organized financial markets (including those for issuers of traded financial instruments) should be publicly disclosed.

    6.1.4 Where financial agencies charge fees to financial institutions, the structure of such fees should be publicly disclosed.

    6.1.5 Where applicable, formal procedures for information sharing and consultation between financial agencies (including central banks), domestic and international, should be publicly disclosed.

    6.2 Significant changes in financial policies should be publicly announced and explained in a timely manner.

    6.3 Financial agencies should issue periodic public reports on how their overall policy objectives are being pursued.

    6.4 For proposed substantive technical changes to the structure of financial regulations, there should be a presumption in favor of public consultations, within an appropriate period.

    VII. Public Availability of Information on Financial Policies

    7.1 Financial agencies should issue a periodic public report on the major developments of the sector(s) of the financial system for which they carry designated responsibility.

    7.2 Financial agencies should seek to ensure that, consistent with confidentiality requirements, there is public reporting of aggregate data related to their jurisdictional responsibilities on a timely and regular basis.

    7.3 Where applicable, financial agencies should publicly disclose their balance sheets on a preannounced schedule and, after a predetermined interval, publicly disclose information on aggregate market transactions.

    7.3.1 Consistent with confidentiality and privacy of information on individual firms, aggregate information on emergency financial support by financial agencies should be publicly disclosed through an appropriate statement when such disclosure will not be disruptive to financial stability.

    7.4 Financial agencies should establish and maintain public information services.

    7.4.1 Financial agencies should have a publications program, including a periodic public report on their principal activities issued at least annually.

    7.4.2 Senior financial agency officials should be ready to explain their institution’s objective(s) and performance to the public, and have a presumption in favor of releasing the text of their statements to the public.

    7.5 Texts of regulations and any other generally applicable directives and guidelines issued by financial agencies should be readily available to the public.

    7.6 Where there are deposit insurance guarantees, policy-holder guarantees, and any other client asset protection schemes, information on the nature and form of such protections, on the operating procedures, on how the guarantee is financed, and on the performance of the arrangement, should be publicly disclosed.

    7.7 Where financial agencies oversee consumer protection arrangements (such as dispute settlement processes), information on such arrangements should be publicly disclosed.

    VIII. Accountability and Assurances of Integrity by Financial Agencies

    8.1 Officials of financial agencies should be available to appear before a designated public authority to report on the conduct of financial policies, explain the policy objective(s) of their institution, describe their performance in pursuing their objective(s), and, as appropriate, exchange views on the state of the financial system.

    8.2 Where applicable, financial agencies should publicly disclose audited financial statements of their operations on a preannounced schedule.

    8.2.1 Financial statements, if any, should be audited by an independent auditor. Information on accounting policies and any qualification to the statements should be an integral part of the publicly disclosed financial statements.

    8.2.2 Internal governance procedures necessary to ensure the integrity of operations, including internal audit arrangements, should be publicly disclosed.

    8.3 Where applicable, information on the operating expenses and revenues of financial agencies should be publicly disclosed annually.

    8.4 Standards for the conduct of personal financial affairs of officials and staff of financial agencies and rules to prevent exploitation of conflicts of interest, including any general fiduciary obligation, should be publicly disclosed.

    8.4.1 Information about legal protections for officials and staff of financial agencies in the conduct of their official duties should be publicly disclosed.

    Annex: Definitions of Certain Terms

    To facilitate presentation, certain general terms are used to capture different institutional arrangements in a summary fashion. The following descriptive definitions are used in the Code.

    Central Bank

    The institutional arrangements for assigning responsibility for the conduct of a country’s monetary policy differ among the Fund’s membership. For most Fund members, this responsibility is assigned to the central bank or to a system of constituent national central banks in a multinational central bank arrangement. There are a number of countries, however, where this role is designated to a “monetary authority” or to a “currency board.” To facilitate presentation, the term “central bank” in the Code refers to the institution responsible for conducting monetary policy, which may or may not be a central bank.

    Financial Agencies

    A wide range of institutional arrangements prevail among Fund members with regard to which unit of government carries exclusive or primary responsibility for the regulation, supervision, and oversight of the financial and payment systems. In a few countries, an agency has been established with responsibility for regulating and supervising an array of financial institutions (banking, insurance, and securities firms) and markets (securities, derivatives, and commodity futures). For most countries, the oversight responsibility for the financial sector is shared among several agencies. Thus, responsibility for the conduct of bank regulation and supervision or for bank deposit insurance policies in some countries is assigned to the central bank, or to an independent bank supervisory or deposit insurance agency, or split among several units of government. Similarly, responsibility for the conduct of policies related to the oversight of certain categories of financial institutions is assigned to the central bank or to a specialized agency. In some cases (e.g., payment systems) a public agency oversees the activities of private sector self-regulatory bodies. To facilitate presentation, the phrase “financial agencies” is used to refer to the institutional arrangements for the regulation, supervision, and oversight of the financial and payment systems, including markets and institutions, with the view to promoting financial stability, market efficiency, and client-asset and consumer protection. (Where the central bank carries responsibility for financial policies, some of the good transparency practices listed for financial agencies in Sections V–VIII of the Code are already specified in the transparency practices listed for central banks in Sections I–IV of the Code.)

    Financial Policies

    The term “financial policies” in the Code refers to policies related to the regulation, supervision, and oversight of the financial and payment systems, including markets and institutions, with the view to promoting financial stability, market efficiency, and client-asset and consumer protection.

    Government

    Unless a particular unit of government is specifically identified in the Code, reference to “government” in the Code refers either to the executive branch of government or to a particular ministry or public agency, depending on the issue at hand or the established tradition of government in particular countries.

    In addition to the Bank for International Settlements, the following international and regional organizations and international financial sector groupings were consulted: Basel Committee on Bank Supervision (BCBS), Center for Latin American Monetary Studies (CEMLA), Committee on Payment and Settlement Systems (CPSS), European Central Bank (ECB), International Association of Insurance Supervisors (IAIS), International Finance Corporation (IFC), International Organization of Securities Commissions (IOSCO), Organization for Economic Cooperation and Development (OECD), and the World Bank.

    The practices in this area should be consistent with the principles of the international Monetary Fund’s Code of Good Practices on Fiscal Transparency.

    The principles for transparency procedures listed in this Code, where applicable and adjusted as necessary, apply where a separate public agency has been designated to manage the country’s public debt.

    Refer to the Annex for definitions of financial agencies and financial policies.

    Biographical Sketches

    Richard K. Abrams is an Advisor in the Monetary and Financial Systems Department (MFD), formerly Monetary and Exchange Affairs, of the International Monetary Fund. Before moving to MFD, he held various positions in the European and Policy Development Departments of the IMF. Prior to joining the IMF, Mr. Abrams worked at the Federal Reserve Bank of Kansas City. He is the author of numerous articles on finance as well as banking and banking supervision. Mr. Abrams obtained his Ph.D. in economics from the University of North Carolina at Chapel Hill.

    Mark Allen received his Bachelor of Arts in mathematics and economics from Cambridge University in 1970. Thereafter, he completed two years of graduate studies in economics at Yale University, followed by one year at the Karl Marx Higher Economic Institute of Sofia, Bulgaria. He began his career with the International Monetary Fund as an economist in the Trade and Payments Division in 1974. He also served as an economist in the IMF’s Geneva Office and as Senior Resident Representative in Poland. In 1994, he was named Deputy Director, Immediate Office, Policy Development and Review Department.

    Tobias M.C. Asser received his law degree from Leyden University, the Netherlands, and his Ph.D. in private international law from Cambridge University. Before he joined the Legal Department of the International Bank for Reconstruction and Development (World Bank) in 1968, he was a practicing attorney in Amsterdam. Among other positions, he served at the World Bank as Assistant General Counsel, Operations, and Assistant General Counsel, Finance. In 1987, Mr. Asser transferred from the World Bank to the International Monetary Fund, where he served as Assistant General Counsel until his retirement in 1999. Since 1985, Mr. Asser has been Adjunct Professor of Law at the Georgetown University Law Center in Washington, D.C., where he teaches international finance and private international law.

    Roy C.N. Baban, formerly Senior Counsel in the Legal Department of the International Monetary Fund, received the degrees of J.D. and LL.M.(Taxation) from Georgetown University Law Center, M.P.A. from Harvard University, and Ph.D. in economics from the University of Manchester (U.K.). He has served as an adjunct faculty member for international banking at the George Washington Law School and on the law of international financial institutions at the Summer Law Institute of the Colleges of Law of Case Western, Cleveland State, and St. Petersburg State Universities. He has conducted workshops on monetary and financial law for the Southeast Asian Central Banks (SEACEN) Research and Training Centre. Mr. Baban is a consultant, focusing on IMF legal matters, banking, and exchange control.

    Tomás J.T. Baliño is Senior Advisor in the Monetary and Financial Systems Department of the International Monetary Fund. Since obtaining his Ph.D. in economics from the University of Chicago, Mr. Baliño has served at the Central Bank of Argentina as well as the IMF for numerous years. He has extensive experience in financial restructuring, corporate transparency, and examining monetary systems.

    Thomas C. Baxter, Jr., received his B.A. from the University of Rochester in 1976 and his J.D. from the Georgetown University Law Center in 1979. He joined the Federal Reserve Bank of New York as an attorney in 1980 after serving as a law assistant to the Appellate Division of the New York Supreme Court. Currently, he is General Counsel and Executive Vice President of the Bank. He also serves as deputy general counsel of the Federal Open Market Committee. In addition, he has served as a legal advisor to the Current Payment Methods project of the National Conference of Commissioners on Uniform State Laws. Mr. Baxter has published articles on legal aspects of bank supervision, check collection, securities transfers, and electronic transfers of funds. He is a joint author of two textbooks, Wire Transfers: A Guide to U.S. and International Laws Governing Funds Transfers (Probus, 1993) and The ABC’s of the UCC: Article 4A Funds Transfers (ABA, 1997).

    William Blair graduated from Balliol College, Oxford, and was called to the English Bar in 1972. His practice focuses on banking and financial law. He has appeared in many leading cases and has an extensive international advisory practice. His publications include the Encyclopedia of Banking Law, which is now published online as part of Butterworths banking law direct service. He became the Queen’s Counsel in 1994. Mr. Blair sits as a Recorder of the Crown Court and is a Visiting Professor at the London School of Economics and the Centre for Commercial Law Studies.

    Michael Bradfield has extensive experience in legal aspects of U.S. and non-U.S. banking and monetary matters. His areas of expertise also include balance of payments and trade and development assistance, including U.S. participation in the international development banks. Prior to becoming general counsel of the Federal Reserve Board, he was in private law practice in Washington, D.C. from 1975 to 1981 with the law firm of Cole, Corette & Bradfield. In that capacity, he practiced in the areas of international finance and trade law as well as in resolving international claims.

    Marco Cangiano has been with the International Monetary Fund since 1991, and currently serves as Assistant to the Director of the Fiscal Affairs Department (FAD). In addition to FAD, he has worked in the Asia and Pacific Department for five years. Prior to joining the IMF, Mr. Cangiano was an economist with the research department of ENI (Italian state oil company), and a consultant for cost benefit and financial feasibility studies for private companies and for the Italian government. He graduated from La Sapienza University in Rome and has a Master of Science in public finance from the University of York.

    Mark Cymrot is an attorney with the law firm Baker & Hostetler LLP in Washington, D.C. concentrating his practice on international and commercial litigation and arbitration. He has represented both private clients and governments. Prior to joining Baker & Hostetler LLP, Mr. Cymrot served as Special Litigation Counsel in the U.S. Justice Department. In addition to his work with the American Bar Association Working Group’s assessment of the Foreign Sovereign Immunities Act, Mr. Cymrot has published numerous articles on litigation and sovereign debt issues. He received his B.A. from George Washington University in 1969 and his J.D. from Columbia University in 1972.

    Gregory C. Dahl received his graduate degree in economics from Harvard University. He joined the IMF in 1976 and has worked on a variety of countries including Pakistan, Nigeria, and Algeria. He has been posted overseas three times as the IMF’s resident representative: in Haiti, Sierra Leone, and, most recently, Bulgaria. He is currently Advisor in the IMF Institute, where he provides training to country officials and IMF economists.

    Ross S. Delston is a legal practitioner in Washington, D.C. specializing in banking law. He is also a legal consultant to the IMF and the World Bank on bank regulatory, insolvency, and deposit insurance issues. From 1991 to 1994, Mr. Delston was Of Counsel to the law firm of Jones, Day, Reavis &. Pogue where he specialized in bank mergers and acquisitions. From 1986 to 1991, Mr. Delston was an attorney with the FDIC. From 1976 to 1986, Mr. Delston was an attorney specializing in trade finance with the U.S. Export-Import Bank. He is the author of Statutory Protections for Banking Supervisors, a 1999 survey of the laws of 20 countries. Mr. Delston received his B.A. (with special honors) in 1973 and his J.D. (with honors) in 1976 from The George Washington University.

    Rainer Geiger is Deputy Director of the Directorate for Financial, Fiscal and Enterprise Affairs of the Organization for Economic Cooperation and Development. Mr. Geiger has also served as Professeur Adjoint at the Université Paris I (Panthéon—Sorbonne).

    François Gianviti studied at the Sorbonne, the Paris School of Law, and New York University. He obtained a licence ès lettres from the Sorbonne in 1959, a licence en droit from the Paris School of Law in 1960, a diplôme d'études supérieures de droit pénal et science criminelle in 1961, a diplôme d'études supérieures de droit privé in 1962, and a doctorat d'Etat en droit in 1967. From 1967 to 1969, he was a Lecturer in Law, first at the Nancy School of Law and subsequently at the Caen School of Law. In 1969, Mr. Gianviti obtained the agrégation de droit privé et science criminelle of French universities and was appointed Professor of Law at the University of Besançon From 1970 through 1974, he was seconded to the Legal Department of the International Monetary Fund, where he served as Counsellor and, subsequently, as Senior Counsellor. In 1974, he became Professor of Law at the University of Paris XII, where he taught civil and commercial law, banking and monetary Law, and private international law. He served as Dean of its School of Law from 1979 through 1985. In 1986, Mr. Gianviti became Director of the Legal Department and, in 1987, General Counsel of the International Monetary Fund, He is a member of the Committee on International Monetary Law of the International Law Association and has published books on property and many articles on aspects of French and international law.

    Michael Gruson has been a partner of Shearman & Sterling since 1973 and is now Of Counsel. He has been primarily engaged in the representation of foreign banks and in international securities transactions. He received his legal education in Germany and in the United States (LL.B., 1962, University of Mainz; M C.L., 1963, Columbia University; LL.B., 1965. cum Laude, Columbia University; Dr. jur., 1966, Freie Universität Berlin). Mr. Gruson is a past Vice-Chairman of the Committee on Banking Law and the past Chairman (1984–1995) of the Subcommittee on Legal Opinions of the Committee on Banking Law of the International Bar Association. He has also served as a lecturer at various law schools including the University of Illinois at Urbana-Champaign, Columbia University School of Law, and the University of Osnabrück, Germany, and he is a visiting Professorial Fellow at the Centre for Commercial Law Studies, Queen Mary and Westfield College, University of London. Mr. Gruson is the author of a number of publications on banking and securities law and has frequently lectured on these topics.

    Gregor Heinrich is presently Head of the Secretariat to the Committee on Payment and Settlement Systems (CPSS) at the Bank for International Settlements (BIS) in Basle, Switzerland. He studied law and romance languages in Bonn, Lausanne, and Hamburg and holds a German law degree from the University of Hamburg as well as a Second State Degree in Law from the State of Hamburg with admission to the bar (“Assessor”) in Germany. After completing his law studies, he worked as assistant to the Faculty of Law at Hamburg University. From 1982 to 1984, when he joined the BIS, he held a research position at the Max Planck Institute for Foreign and Private International Law in Hamburg and worked as an attorney for the law offices of Franke & Jacob in Hamburg. Mr. Heinrich has published several articles on various aspects of comparative law. He is a member of the Editorial Council of the journal, “Payment Systems Worldwide,” of the International Advisory Council for the World Bank’s “Western Hemisphere Payments Initiative,” and a member of the Consultative Group on the Supporting Document to the IMF Code of Good Practices in Monetary and Financial Policies.

    Ricki Tigert Helfer is a law professor at the Washington College of Law of American University, where she teaches domestic and international banking and finance. She previously served as Chairman and Chief Executive Officer of the Federal Deposit Insurance Corporation (FDIC) in Washington, D.C While Chairman of the FDIC, Ms. Heifer was a member of the Basle Committee on Banking Supervision. Ms. Heifer has previously served as a Nonresident Senior Fellow at The Brookings Institution in Washington. She has also served for seven years as the senior international lawyer for the Board of Governors of the Federal Reserve System in Washington and was a Governor of the Philadelphia Stock Exchange. Ms. Helfer has contributed to a wide range of publications, including articles and chapters in books, on banking and financial issues. Ms. Heifer graduated with honors from the University of Chicago Law School and has an M.A. in political development from the University of North Carolina at Chapel Hill. She received her B.A., magna cum laude, from Vanderbilt University and served as a law clerk at the U.S. Court of Appeals for the Fifth Circuit.

    John Hicklin received his B.A. and M.A. in modern history and economics from University College, Oxford, and his M.Sc. in economics from the London School of Economics. He is currently Senior Advisor in the Policy Development and Review Department of the International Monetary Fund. He has also held positions in other departments, including the Middle Eastern and Asia and Pacific Departments, and the Office of the Deputy Managing Director, since joining the IMF in 1982 from H.M. Treasury.

    Luis Jácome Hidalgo is a senior economist in the Monetary and Financial Systems Department of the International Monetary Fund, having served previously as a Technical Assistance Advisor in the same department. Mr. Hidalgo has held positions with the Central Bank of Ecuador, the Ministry of Finance, and the Corporación de Estudios para el Desarrollo. Mr. Hidalgo obtained his undergraduate degree in macroeconomics from the Universidad Computeres, an M.Sc. in macroeconomics from Queen Mary College, and a Ph.D. in international economics from Boston University.

    William E. Holder received his LL.B. and B.A. from the University of Melbourne. He subsequently earned an LL.M. from Yale University and a Diploma from the Hague Academy of International Law. He has served as a Tutor in Law at the University of Melbourne, a Professor of Law at the University of Mississippi, a Reader in Law at the Australian National University, and an advisor on international law for the Australian Department of Foreign Affairs. Mr. Holder joined the International Monetary Fund in 1976 and has served as Deputy General Counsel since 1986. He is coeditor of The International Legal System: Cases and Materials with Emphasis on the Australian Perspective (Butterworths, 1972) and is the author of many articles on international law.

    George Iden is a senior economist in the Monetary Operations Division in the Monetary and Financial Systems Department (MFD), formerly the Monetary and Exchange Affairs Department. He served on a departmental task force that was assigned to work on the Code of Good Practices on Transparency in Monetary and Financial Policies and an associated Supporting Document to the Code. In this connection, he coordinated a Regional Consultative Meeting on the Code held in Abu Dhabi and participated in another such meeting in Singapore. He has also participated in several missions that have focused on issues associated with transparency in monetary policy, including Hong Kong SAR, Russia, and Ghana. Mr. Iden, who has his Ph.D. in economics from Harvard, joined the International Monetary Fund in 1992. Before joining the IMF, he worked for the U.S. Congressional Budget Office (CBO) where he served as Chief of the Special Studies Unit. Prior to CBO, he taught economics at American University and the University of North Carolina, Chapel Hill, and served as an economist for the Joint Economic Committee of the U.S. Congress.

    Alain Ize received an engineering degree from L'Ecole Centrale de Paris, an M.B.A. from Columbia University, and a Ph.D. in engineering economic systems from Stanford University. Before joining the Monetary and Financial Systems Department of the International Monetary Fund, in which he currently serves as Advisor, he held various positions in the Fiscal Affairs Department. He joined the IMF in 1985 after holding teaching, research, and consulting positions at the Colegio de Mexico and Banco de Mexico.

    Karen H. Johnson is Director of the Division of International Finance at the Board of Governors of the Federal Reserve System, a position she has held since October 1998. Ms. Johnson earned a Ph.D. in economics from the Massachusetts Institute of Technology in 1973 and later joined the faculty of the economics department of Stanford University, where she taught for six years. In 1979, she moved to Washington, D.C., as an economist in the Division of International Finance at the Federal Reserve Board. She became Chief of the World Payments and Economic Activity Section in 1984, Assistant Director of the Division of International Finance in 1985, and Associate Director in 1997.

    Omotunde E.G. Johnson studied economics at the University of California, Los Angeles (UCLA), where he received his B.A. in 1965 and Ph.D. in 1970. He was Lecturer at the University of Sierra Leone (1969–73) and Visiting Assistant Professor and Research Associate at the University of Michigan (1973–74). before joining the International Monetary Fund in 1974 In the IMF he has worked in the Exchange and Trade Relations Department (now the Policy Development and Review Department), the African Department, the Research Department, and, since 1990, the Monetary and Financial Systems Department, formerly Monetary and Exchange Affairs, where he was formerly Assistant Director. He was also IMF Resident Representative in Ghana during 1987–90. Mr. Johnson has written on various topics in the field of economics and coauthored a book, Payment Systems, Monetary Policy, and the Role of the Central Bank, published by the IMF in I998.

    Jennifer Johnson-Calari is a Principal Investment Officer, Investment Management Department (IMD), World Bank. She joined the IMD ten years ago and has been responsible for client investment strategy. Since joining the IMD, she has been a fixed income portfolio manager in all of the major currency blocs and has had responsibility for the fixed income sector of the pension plan. Before joining the World Bank, she was with the Comptroller of the Currency where she specialized in multinational bank management of market risks. From 1981 to 1988, she was with the Board of Governors of the Federal Reserve System in international bank supervision. She holds a master’s degree in international economics from the Johns Hopkins University and is a Chartered Financial Analyst.

    Ross Leckow is Senior Counsel in the Legal Department of the International Monetary Fund. Mr. Leckow holds a B.A. (Honors) from the University of Winnipeg, an LL.B. from the University of Manitoba, and an LL.M. from York University (Canada), Previously, he served as Legal Counsel in the Legal Services Division and Treasury Officer in the Corporate Finance Department of the Export Development Corporation of Canada.

    John Jin Lee is Vice President and Managing Senior Counsel at Wells Fargo Bank, N.A.. In this capacity, he has extensive experience with legal issues in retail banking, ranging from depositary matters to consumer credit transactions and cyberspace banking. Prior to joining the bank in 1977, Mr. Lee was an associate in the law firm of Manatt, Phelps & Rothenberg. He graduated magna cum laude with a B.A. from Rice University in 1971 and received his J.D. and M.B.A. from Stanford University in 1975. Mr. Lee has served on various committees of the American Bar Association in the area of financial services. He is also a member of the Lawyers Committee of the Consumer Bankers Association and has been elected to the American College of Consumer Financial Services Attorneys. Mr. Lee has written numerous articles for The Business Lawyer and other publications. He is a member of the California State Bar.

    Jerome I. Levinson is a graduate of the Harvard College, 1953, and the Harvard Law School, 1956. He was a Fulbright scholar in India, 1956–57. He is presently the Distinguished Lawyer in Residence at the Washington College of Law, where he has been for the last five years. Professor Levinson previously served as Assistant Director of the Agency for International Development Office in Brazil (1964–66); Deputy Director of the AID Latin American Capital Assistance program (1966–68); Chief Counsel to the Senate Foreign Relations Committee, Sub-Committee on Multinational Corporations and U.S. Foreign Policy (1972–77); General Counsel to the Inter-American Development Bank (1977–89); and Of Counsel to the Washington law firm of Arnold & Porter (1990–92). Professor Levinson is also currently a research associate of the Economic Policy Institute.

    Cynthia Lichenstein is a visiting professor at George Washington University School of Law after retiring from active teaching at Boston College Law School in the spring of 2001. Ms. Lichtenstein graduated magna cum laude from Radcliffe College in 1955, and earned her J. D. magna cum laude from Yale University in 1959. She also holds a master’s degree in Comparative Law from the University of Chicago. Ms. Lichtenstein began her career by association with a major New York law firm where she specialized in international banking, returning to the same firm in the 1980s. In 1971, she joined the faculty of Boston College Law School, where she was one of the first female professors. She was elected President of the American Branch of the International Law Association in 1986, has served as chair of the ILA’s International Securities Regulation Committee, and has been a member of the Board of Editors of the American Journal of International Law. Ms. Lichtenstein also served as a guest scholar in the Legal Department of the International Monetary Fund in early 2000.

    Jean-Victor Louis is professor at the European University Institute, Florence, and at the Université Libre de Bruxelles. He has also been a visiting professor at the Université de Paris 1 (Panthéon-Sorbonne) and the Université Robert Schuman at Strasbourg, He is the president of the “Study Group on European Politics” (the Belgian branch of the TransEuropean Political Studies Association (TEPSA)). From 1980 to 1992, he was the president of the Institute of European Studies of the ULB and, up to 1998, Head of the Legal Department of the National Bank of Belgium. He is now honorary General Counsel of the NBB. He has published extensively on institutional and other aspects of European Community Law, especially in the field of EMU, and on external relations law of the EU.

    Carol Mates is Principal Counsel with the International Finance Corporation, the private-sector affiliate of the World Bank. At the IFC, she specializes in project finance and particularly the financing of private infrastructure projects. Her work has entailed syndication of loans with banks in Asia, Europe, and the United States, as well as cofinancing arrangements with bilateral and other multilateral development agencies and local development banks. She obtained her A.B. from Barnard College and J.D. from Columbia Law School.

    John W. Moscow is Deputy Chief of the Investigations Division of the New York County District Attorney’s Office, where he started prosecuting street crime in 1972. He has spent more than 20 years prosecuting thefts, tax fraud, money laundering, securities fraud, and bank fraud. A graduate of the University of Chicago and Harvard, his best known case is the prosecution of the Bank of Credit and Commerce International (BCCI).

    Erwin Nierop studied law at the State University of Leiden, the Netherlands. He then joined the legal department of the Dutch Central Bank in Amsterdam. Subsequently, he served as member of a team that set up the European Bank for Reconstruction and Development in London; member of the Secretariat of the Committee of Governors of the Central Banks of the Member States of the European Economic Community at the Bank for International Settlements in Basle, Switzerland, which created the basis for the European Monetary Institute; and Deputy General Counsel of the European Monetary Institute in Frankfurt am Main, Germany. Mr. Nierop is presently Deputy General Counsel and Head of the Financial Law Division of the European Central Bank, based in Frankfurt am Main.

    Joseph Norton holds an A.B. from Providence College; an LL.B. from the University of Edinburgh; an LL.M from the University of Texas; a Diplôme (droit privé) from the Hague Academy of International Law; an S.J.D. from the University of Michigan; and a D.Phil. (Law) degree from Oxford University. He has held appointments at the Centre for Commercial Law Studies-University of London; the Southern Methodist University (SMU) Law School; and the University of Hong Kong. He has served as editor-in-chief of The International Lawyer and the Yearbook of International Financial and Economic Law as well as other international legal publications. He has been a visiting professor at Soochow University, Taipei; the University of Tokyo Law Faculty; and the University of Münster, Germany. He is Executive Director of the London Institute of International Banking, Finance and Development Law, and of the SMU Institute of International Banking and Finance. Before joining the SMU law faculty full time in 1981, Professor Norton was a director of a major Dallas law firm, practicing in the banking/capital markets/corporate areas. He has written more than 120 articles, chapters, and research monographs on domestic and international business and banking matters.

    Roberts B. Owen, a graduate of the Harvard Law School and Cambridge University, practiced law as a litigator for Covington &Burling of Washington, D.C., for many years and has now retired from the litigation practice. He served as the Legal Adviser to the U.S. Department of State in 1979–81 and as Senior Adviser to the Secretary of State in 1995–99, He participated in drafting the 1981 Algerian Accords (establishing the U.S.-Iran Claims Tribunal) and the 1995 Dayton Accords. He continues to practice as an international arbitrator. He is a member of the arbitration panels of the International Center for Settlement of Investment Disputes and the Claims Resolution Tribunal for Dormant Accounts in Switzerland.

    Vincent Raymond Reinhart is Director of the Division of Monetary Affairs at the Board of Governors of the Federal Reserve System and Secretary of the Federal Open Market Committee since July 2001. Previously, he was Deputy Director of the Division of International Finance for two years and held a variety of positions in the Division of Monetary Affairs. Before joining the Board in 1988, he was Senior Economist in the International Research Department of the Federal Reserve Bank of New York. His academic publications primarily concern the conduct of policy and issues related to the monetary transmission mechanism as well as an analysis of alternative Treasury auction techniques and Treasury debt management. After his undergraduate training at Fordham University, he received graduate degrees in economics at Columbia University.

    Antonio Sáinz de Vicuña is a graduate in economic sciences and law, Universidad Complutense de Madrid, and received a Diploma in International Law, Cambridge University (U.K.). He is a member of the Corps of Government Attorneys (Abogado del Estado). He served as Legal Adviser to the Ministry of Finance (1974–77), the Deputy Prime Minister and Minister of Economy (1977–78), the Ministry of Foreign Affairs (1979–85), the Secretariat of State for the European Communities (1980–83), and as Chief Legal Adviser to the Ministry of Foreign Affairs (1985–87). He was Chief International Legal Counsel of the Banco Español de Crédito (1987–94), General Counsel of the European Monetary Institute (Frankfurt) (1994–98), and General Counsel of the European Central Bank (since 1998). He serves as Chairman of the Legal Committee of the European System of Central Banks (ESCB) and a Member of the International Monetary Law Committee. He is the author of International State Contracts (La contratación exterior del Estado), and of some 20 professional articles on Community, International, and Banking Law.

    Pamela Sak is a member of the Financial Transactions Practice of Jones Day, specializing in the areas of banking and corporate matters. Prior to joining Jones Day, she worked in the Legal Department of the International Monetary Fund, where she gained broad experience in banking, commercial, monetary, and international law. Ms. Sak is a member of Women in Housing and Finance and cochair of its International Task Force. She is a coauthor of Swiss Law on the Treatment of Dormant Accounts and Bankruptcy Law Reform in Eastern Europe and is author of Environmental Law in Ukraine.

    Garry J. Schinasi received his Ph.D. in economics from Columbia University in 1979. He worked on the staff of the Board of Governors of the U.S. Federal Reserve System from 1979 to December 1989, when he joined the staff of the International Monetary Fund. Mr. Schinasi is currently the Chief of the International Capital Markets and Financial Studies Division in the International Monetary Fund’s Research Department, which is responsible for writing the IMF’s annual International Capital Markets Report. He has published articles in The Review of Economic Studies, Journal of Economic Theory, Journal of International Money and Finance, and other academic and policy journals. His recent research has focused on international capital markets, the interplay of monetary and financial stability, and the relevance of asset prices in the formulation of monetary and financial policies.

    Brian W. Smith is a partner in the Washington, D.C., office of Mayer, Brown & Platt where he heads the Financial Regulatory and e-commerce practices of the firm. Mr. Smith was formerly chief counsel to the Office of the Comptroller of the Currency and a member of the Comptroller’s Policy Group. Formerly, he was senior vice president, general counsel, and corporate secretary to MasterCard International, Inc. Mr. Smith received his undergraduate and law degrees from St. John’s University in New York and a master’s degree from Columbia University’s Graduate School of Business.

    Kazuaki Sono is currently Dean and Professor of Law, Faculty of Law and Policy, Tezukayama University, Nara; Professor Emeritus, Hokkaido University, Sapporo; and served as Secretary of the United Nations Commission on International Trade Law (UNCITRAL) and Chief of the International Trade Law Branch, Office of Legal Affairs, United Nations, 1980–85. Formerly, he served as Assistant General Counsel in the Legal Department of the International Monetary Fund, 1990–93. He has also been a member of the International Monetary Law Committee of the International Law Association (ILA) since 1979. Mr. Sono holds an LL.M. from Kansai University and a J.D. from the University of Washington.

    Bernhard Steinki is Counsel in the Legal Department of the International Monetary Fund. He obtained his law degree (1. Juristisches Staatscxamen) from the University of Freiburg in 1992 and has a Master of Laws degree from the University of London (King’s College). After completing his professional training (Rechtsreferendariat), Mr. Steinki joined the Legal Department of the Deutsche Bundesbank in 1996 where he worked on a broad range of issues of preparatory work for European Monetary Union. He joined the Legal Department of the IMF in April 1999.

    Michael W. Taylor is currently the Monetary and Financial Systems Department’s Financial Sector Issues Representative in Indonesia, where he is engaged in financial sector reform issues. He holds his D.Phil. and B.A. from Oxford University and before joining the IMF, he was Reader in Financial Regulation at Reading University (U.K.) and worked for six years with the Bank of England.

    Victor Thuronyi received his undergraduate degree in economics from Cambridge University and his law degree from Harvard Law School. He joined the International Monetary Fund’s Legal Department in 1991. He has practiced tax law, served in the U.S. Treasury Department, and taught tax law at several law schools. Mr. Thuronyi, who currently serves as Senior Counsel (Taxation) of the IMF, has supervised and participated in legislative drafting projects for roughly 40 countries. He is the author of several articles on taxation and editor of a book, Tax Law Design and Drafting.

    Robert B. Toomey has been Counsel at the Federal Reserve Bank of New York since December 1997. Prior to joining FRBNY in 1995, Mr. Toomey spent three years with the Securities and Exchange Commission in the Division of Corporation Finance. From 1987 to 1992 he was an associate with Reid & Priest in New York. Mr. Toomey currently serves as Secretary to the Financial Markets Lawyers Group and acts as Counsel to the Foreign Exchange Committee. He received his B.A. from Haverford College and his J.D. from Fordham University Law School.

    Jan-Willem van der Vossen is Deputy Division Chief in the Banking Supervision and Regulation Division of the Monetary and Financial Systems Department (MFD), formerly Monetary and Exchange Affairs of the International Monetary Fund. Prior to taking up the position of Deputy Division Chief, Mr. van der Vossen served as Technical Assistance Advisor from 1993 to 1997 and as Senior Economist from 1997 to 1999. Before joining the IMF in 1993, he held positions in the private sector as well as with the Netherlands Ministry of Foreign Affairs. Mr. van der Vossen obtained his M.A. in Law from Leyden University in 1970.

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