The undersigned United States and international nongovernmental organizations (NGOs) are pleased to submit a public comment regarding the “Reporting Requirements on Responsible Investment in Burma.” Many of our organizations have expressed concerns about the scope and timing of the US government decision to permit new investment in Burma and argued for stronger requirements to be imposed on American companies in view of serious, ongoing human rights and corruption concerns. We nevertheless support the reporting requirements as a valuable–if incomplete and imperfect–means to help advance human rights and political reform, consistent with the US government’s longstanding foreign policy priorities in Burma.

We write to you to share our recommendations for the World Bank Group as it re-engages with Burma. The Group has a rare opportunity to shape the development agenda in Burma by pressing for enhanced transparency, accountability, and respect for human rights through the re-engagement process. Experience elsewhere has shown that if these reforms do not take place early in a transition, they are much more difficult to achieve later on. The Group should ensure the proper sequencing, priorities, and safeguards for its programs in Burma.

We understand that you have been invited by the Leon H. Sullivan Foundation (Sullivan Foundation) to participate in its IX Sullivan Summit, which is scheduled to take place in Malabo, Equatorial Guinea, from August 20-24, in collaboration with President Teodoro Obiang Nguema Mbasogo. The selection of President Obiang as the host of the upcoming summit is controversial, particularly given the Sullivan Foundation’s mission of empowering underprivileged people and the event’s intended focus on economic and social development in Africa.