Matteson Ellis commented on how the World Bank's anti-corruption unit, Integrity Vice Presidency (INT), has gone through a transitional year and faced investigative challenges caused by the pandemic. The bank had opened 40 new investigations between July 2020 and June 2021, which was slightly less than previous years, according to the anti-corruption unit's latest annual report. INT's annual report also showed a steady stream of corporate settlements for conduct including corruption, fraud and collusion, numbers that are consistent with previous years. The fact that settlements generally remained steady over the last few years shows that the "concept of settlement is now well-established" especially in fraud cases, Ellis said. "Settlement is now a real, viable and pragmatic option for many companies when facing the potential for a sanction proceeding," Ellis noted, adding that "It's easier to establish fraud and I think respondents in these proceedings are learning that, and, perhaps because of that, are choosing to engage in settlement discussion more readily rather than fight the charges through the sanction proceedings."