Governance of Global financial...

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Cambridge University Press978-0-521-76266-3 - Governance of Global Financial Markets: The Law, The Economics,The PoliticsEmilios AvgouleasFrontmatterMore information

Gov er na nce of Globa l fi na nci a l M a r k ets

The recent financial crisis proved that pre-existing arrangements for the governance of global markets were flawed. With reform underway in the Us, the eU and elsewhere, emilios avgouleas explores some of the questions associated with building an effective governance system and analyses the evolution of existing structures. by critiquing the soft law structures dominating international financial regulation and examining the roles of financial innovation and of neo-liberal policies in the expan-sion of global financial markets, he offers a new epistemological reading of the causes of the Global financial crisis. requisite reforms leave serious gaps in cross-border supervision, in the resolution of global financial institutions and in the monitoring of risk originating in the shadow banking sector. to close these gaps and safe-guard the stability of the international financial system, an evolutionary governance system is proposed that will also enhance the welfare role of global financial markets.

e m i l ios avg ou l e a s holds the chair of international banking law and finance at the law school of the University of edinburgh. He was previously the Professor of international financial Markets and financial law at the University of Manchester. He also holds a number of visiting professorships and has written extensively in the wider field of financial law and economics, behavioural finance and financial regulation, and eU financial services law.

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international corporate law and financial market regulation

corporate law and financial market regulation matter. The Global financial crisis has challenged many of the fundamental concepts underlying corporate law and financial regulation; but crisis and reform has long been a feature of these fields. a burgeoning and sophisticated scholarship now challenges and contextualizes the contested rela-tionship between law, markets and companies, domestically and internationally. This series informs and leads the scholarly and policy debate by publishing cutting-edge, timely and critical examinations of the most pressing and important questions in the field.

Series EditorsProfessor eilis ferran, University of cambridgeProfessor niamh Moloney, london school of economics and Political scienceProfessor Howell Jackson, Harvard law school

Editorial BoardProfessor Marco becht, Professor of finance and economics at Université libre de

bruxelles and executive Director of the european corporate Governance institute (ecGi).

Professor brian cheffins, s. J. berwin Professor of corporate law at the faculty of law, University of cambridge.

Professor Paul Davies, allen & overy Professor of corporate law and Professorial fellow of Jesus college, University of oxford.

Professor luca enriques, Professor of business law in the faculty of law at the University of bologna.

Professor Guido ferrarini, Professor of business law at the University of Genoa and fellow of the european corporate Governance institute (ecGi).

Professor Jennifer Hill, Professor of corporate law at sydney law school.Professor klaus J. Hopt, Director of the Max Planck institute of comparative and

international Private law, Hamburg, Germany.Professor Hideki kanda, Professor of law at the University of tokyo.Professor colin Mayer, Peter Moores Professor of Management studies at the saïd

business school and Director of the oxford financial research centre.James Palmer, Partner of Herbert smith, london.Professor Michel tison, Professor at the financial law institute of the University of

Ghent, belgium.andrew Whittaker, General counsel to the board at the Uk financial services

authority.Professor eddy Wymeersch, former chairman of the committee of european

securities regulators (cesr), former chairman of the iosco european regional committee and Professor of commercial law, University of Ghent, belgium.






Gover na nce of Globa l fina ncia l

M a r k ets

The law, The economics, The Politics

eMilios avGoU leas






C A M BR I D GE U N I V E R SI T Y PR E S Scambridge, new York, Melbourne, Madrid, cape town,

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© emilios avgouleas 2012

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first published 2012

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in loving memory of my father evangelos






vii

c o n t e n t s

Foreword page xiiiPreface xvList of abbreviations xx

1 introduction 11 The autumn of 2008 12 Why the Gfc was not prevented? 23 Why is finance so important? 4

3.1 overview 43.2 should finance be regulated? 6

4 The post-2008 reforms 85 Whither governance of global financial markets? 12

5.1 The book’s subject matter 125.2 towards a new governance model 12

6 book structure 15

Part I Financial markets and financial crises

2 financial markets and financial crises 211 introduction 212 The important functions of the financial system 23

2.1 How financial systems foster economic growth 232.2 Mobilization, pooling of savings and ease of

exchange 242.3 information production, facilitation of investor (saver)

monitoring and capital allocation 262.4 risk management and risk reduction 272.5 corporate governance 292.6 evidence of the strong link between developed financial

systems and economic growth 302.7 fsD, availability of finance and poverty alleviation 32






Contentsviii

3 evolution of global markets and financial innovation 353.1 complex instruments and international financial markets 353.2 The different classes of derivatives contracts 363.3 securitization and structured finance 403.4 credit derivatives 473.5 shadow banking 51

4 efficient markets, inefficient markets, adaptive markets 544.1 introductory remarks 544.2 efficient Markets Hypothesis versus behavioural

finance 574.3 other puzzles 614.4 adaptive markets 62

5 The neo-liberal consensus policies and the growth of global financial markets 645.1 The Jackson Hole consensus 645.2 Deregulation 675.3 Washington consensus policies 70

6 financial markets and financial crises 726.1 The asian crisis 726.2 The Global financial crisis 746.3 are financial markets inherently unstable? 79

7 summary of findings 88

3 The causes of the Global financial crisis 891 introduction 892 Macro-causes 92

2.1 Global trade imbalances and lax monetary policies 92

2.2 The flawed use of financial innovation 962.3 failed government policies 1062.4 neo-liberal economic doctrine and deregulation 1102.5 irrational exuberance and other behavioural causes 121

3 Micro-causes: the issue of misaligned incentives 1263.1 executive compensation and corporate governance

failures 1263.2 The ‘originate-to-distribute’ model 1293.3 The flawed information content and use of credit

ratings 130






Contents ix

4 flawed regulations 1334.1 capital and investor protection regulations 1334.2 ‘too-big-to-fail’ institutions and lack of cross-border

special resolution regimes 1345 Market failure, regulatory failure and the financial

revolution 1365.1 an alternative explanation of market and regulatory

failure? 1365.2 complexity, emergence and the Gfc 1425.3 The role of insider rent-seeking 1465.4 a knowledge revolution 150

6 concluding remarks 154

Part II The evolution of governance structures for international finance

4 The evolution of global financial governance and development of international financial regulation 1571 introduction 1572 The bretton Woods and post-bretton Woods

phase 1592.1 introductory remarks 1592.2 Monetary stability – financial stability and the iMf 1622.3 The origins of trns and of standard setting 1652.4 The most important trns of the post-bretton Woods

period 1682.5 reconstruction, development and the World bank 1792.6 trade liberalization and financial services: from the ito

to the Wto 1823 intermediate phase: a ‘new international financial

architecture’ (1998–2008) 1853.1 an overview of the nifa 1853.2 The evolution of standard setting bodies and financial

standards during nifa 1893.3 implementation – monitoring and the fsaP surveys 1993.4 a critique of nifa 203

4 The emerging architecture 2044.1 introductory remarks 2044.2 The emergence of the G-20 2054.3 The iMf 206






Contentsx

4.4 from the fsf to the fsb 2074.5 The supervisory colleges 209

5 summary and concluding remarks 210

5 The ‘softness’ of soft law and global financial governance 2131 introduction 2132 What is international financial regulation? 217

2.1 regulation rationales 2172.2 The advantages of soft law and trns in the context of

global financial governance 2212.3 soft law shortcomings 2252.4 The issue of legitimacy 232

3 can soft law financial governance meet the challenges? lessons from the Gfc 2363.1 introductory remarks 2363.2 The flaws of the basel capital framework 2373.3 regulatory arbitrage through asset transformation,

credit ratings and other follies 2383.4 The systemic implications of neglecting liquidity 2403.5 flawed risk models and procyclicality 243

4 supervisory failures, cross-border crisis management and ‘too-big-to-fail’ institutions 2464.1 overview of the issue 2464.2 a closer look at the kaupthing, fortis and

Dexia cases 2494.3 lack of cross-border resolution regimes and

‘too-big-to-fail’ institutions 2525 What should be done? 256

Part III Regulatory reform and a new governance model for global financial markets

6 regulatory and supervisory reform: Us, eU, bcbs 2611 introduction 261

1.1 overview 2611.2 summary of reforms 262

2 critical aspects of the Dodd–frank act 2722.1 supervision of sifis and systemic risk oversight under

the Dodd–frank act 272






Contents xi

2.2. regulation of derivatives markets under the Dodd–frank act 280

2.3 registration of hedge fund advisers 2883 regulatory and supervisory reform in the eU 289

3.1 The first attempt to reform eU financial regulation 2893.2 The european system of financial supervision 302

4 The new basel capital and liquidity framework 3214.1 Minimum capital requirements and composition of

capital 3214.2 capital buffers 3244.3 containing leverage 3304.4 liquidity ratios 3324.5 risk management and supervision 3414.6 evaluation of basel iii 344

7 Global reform of the ‘too-big-to-fail’ institution and the new resolution regimes in the Us and the eU 3481 introduction 3482 fsb principles for the supervision of sifis 3513 targeting bank size and speculative banking

activities 3523.1 The volcker rule 3523.2 ban on proprietary trading 3543.3 limited sponsoring or investing in private equity and hedge

funds 3563.4 The regime for non-bank financial companies 3583.5 Uk proposals on the structure of the banking industry 359

4 increased capital requirements for sifis and G-sifis 3604.1 contingent capital instruments 3604.2 capital surcharges 368

5 bcbs-fsb principles on cross-border sifi resolution 3705.1 What is the problem? 3705.2 bcbs, fsb and iMf recommendations on cross-border

resolution 3736 The Dodd–frank act resolution regime for sifis 381

6.1 enhanced supervision and failure prevention 3816.2 orderly liquidation authority 3846.3 evaluation 393






Contentsxii

7 The proposed eU crisis management and resolution framework 3947.1 General principles 3947.2 Preparation, early intervention and prevention 3967.3 recovery plans and group recovery plans 4017.4 resolution plans 4037.5 early intervention powers 4077.6 resolution powers and tools 4097.7 financing resolution 4227.8 evaluation of the eU resolution regime 424

8 summary and conclusions 425

8 an evolutionary model for global financial governance 4291 introductory remarks 429

1.1 overview 4291.2 summary of the proposal 432

2 The proposed global regulatory framework 4352.1 General principles: the importance of shared values 4352.2 The global macro-prudential supervisor 4402.3 a global micro-prudential authority 4422.4 Global financial policy, regulation and risk knowledge

authority 4472.5 a global resolution authority 4512.6 other advantages of the proposed governance system 454

3 conclusion 457

Index 460






xiii

f o r e W o r D

Walter bagehot’s classic, Lombard Street, was his response to the financial crisis sparked by the collapse of the overend Gurney bank and to what he saw as the enormity of the potential liabilities of the city of london, which accompanied its great wealth. He wrote: ‘[W]e must examine the system on which these, great masses of money are manipulated, and assure ourselves that it is safe and right’. Professor avgouleas has penned an equally authoritative study of the background to the financial crisis which began in 2007 and the ameliorative steps subsequently taken. He too inquires whether the system is now ‘safe and right’. The answer is not totally reassuring as regards the international operation of the world’s financial giants and the financial revolution they have spawned. in his view what is necessary is a new system of global financial governance, underpinned by an umbrella international treaty.

but this is to anticipate. The detailed and careful analysis which pre-cedes Professor avgouleas’s conclusion begins with a lucid account of the structures and operation of financial markets, identifying their contribu-tion to economic growth but also highlighting their risks and instabilities. Market phenomena such as bubbles and herding feature regularly but in the modern age there have also been developments such as derivatives transactions and shadow banking. That leads to a cogent dissection of the crisis itself and what proved to be the frail machinery available to handle it, not least in its cross-border dimensions. The context of the crisis, as Professor avgouleas explains, was what he characterizes as the financial revolution of the preceding decades – liberalized markets, technological advances and financial innovation, all accentuated by a public policy shot through with neo-liberalism. on reading Professor avgouleas’s account of this financial revolution, one draws the obvious parallel with the industrial revolution and correlative financial change of bagehot’s day. The financial revolution, misunderstood and badly managed, was fertile ground for a crisis when coupled with factors such as the excessive rent-seeking by those associated with finance, their lobbying against effective






forewordxiv

capital requirements and other prophylactic regulation, and their promo-tion of a climate where ‘light touch’ regulation was the order of the day.

Professor avgouleas then turns to international financial governance, with a thoughtful history of the bretton Woods settlement in practice, and of the measures following the asian crisis of the late 1990s and the Global financial crisis a decade later. as would be expected, the iMf and the constellation of basel institutions, such as the financial stability board (née forum) feature prominently. The role of state-to-state groups like the G-20 is also traced. The weaknesses in standard setting and its enforcement post-asian crisis are explored, in particular the basel ii standards for bank capital, which in their formulation were captured by the industry. basel ii is also illustrative of the drawback to the soft law approach to international financial regulation. The meat of Part iii of the book is Professor avgouleas’s outline and critique of post-Global financial crisis measures at national, regional (european Union) and international levels. The reasons for the differences in approach are touched on, as is the constitutional background to the new european supervisory authorities and supervisory colleges. fraught issues are explained such as the countercyclical buffer in basel iii. The reform of the ‘too-big-to-fail’ financial institution and the new resolution regimes are deservedly given extensive treatment.

This is a book of great scholarship. The wealth of learning is astonish-ing. it is drawn from a range of disciplines as varied as finance theory, economics, international relations and law. not everyone will agree with the solutions proffered. in one sense they appear radical but a contextual reading reveals that, like most sensible reforms, they build on what has gone before. anyone pondering the way forward for global financial gov-ernance will need to engage with the considerations Professor avgouleas advances, based as they are on the mature reflections of a leading authority. The book deals with matters which concern ordinary people; as Professor avgouleas notes, it is they who have reaped the consequences of the inter-national havoc wrought by the Global financial crisis in terms of job losses and economic hardship. Deliberation by public policy makers on the contents of the book will inevitably lead them to conclude that vested interests cannot be allowed to continue with ‘business as usual’.

sir ross cranston fba






xv

The collapse of lehman brothers was just the high point of a crisis that started in mid-2007 and continues until this day. This came to be known as the Global financial crisis (Gfc). Policy-makers, regulators, the in-dustry, academics and other stakeholders throughout the world have been grappling with its root causes and consequences on a daily basis for the past four years. The eurozone debt crisis is only its latest manifestation/transformation in a dramatic chain of events that has also led to the near collapse of the world’s biggest financial institutions and their costly public rescues, a major economic recession and heavy over-indebtedness for most Western countries.

Many of the questions raised following the eruption of the Gfc have been answered only in part. Therefore, one of the biggest challenges this work has faced was the possibility of fashioning a new epistemological reading of the causes of the Gfc. This new reading had to build on those causes of the Gfc that have already been well explained, such as, for in-stance, trade imbalances, misaligned incentives and unsustainable debt accumulation. but it also had to try to identify the missing link that allowed those causes to be correlated in open global markets with cata-strophic consequences.

The eruption of the Gfc showed that the preceding regulatory frame-works in the Us and the eU were more or less built on sand, when it came to crisis management, especially cross-border crisis management. in addition, the global financial architecture of the pre-crisis era, largely based on a thick network of soft law bodies, lacked the institutional cap-acity required to deal with a cross-border financial crisis. The rules and standards of those bodies were built on flawed assumptions, which, es-pecially in the case of capital standards, allowed financial institutions to over-leverage their balance sheets operating on a perilously thin equity base. They also did not take into account system-wide develop-ments. Thus, capital adequacy standards intensified rather than con-tained asset bubbles that in most cases precede financial collapses. other

P r e f a c e






Prefacexvi

failures and loopholes clearly observed in the system in the pre-Gfc era were narrow representation, lack of accountability and a significant failure to address the problems created by the integration of global finan-cial markets, including issues of regulatory coverage. national, regional and international regulatory systems, largely informed by neo-liberal ideology, left outside of any meaningful public oversight the global otc derivatives markets and the shadow banking sector, namely, the two most important laboratories/sources of financial innovation and generators of interconnectedness.

a gigantic reform effort is underway in the Us, the eU and globally trying to address the aforementioned loopholes in order to minimize systemic risk and contain the impact of the ‘too-big-to-fail’ institution. requisite reforms have also led to the establishment of a number of new systemic regulators and financial supervisors at all levels. The mandate of these bodies is often complex and their effectiveness remains unverified. nonetheless, it is beyond doubt that most of these reforms are in the right direction and will close major loopholes in the regulation and supervi-sion of global finance. However, this effort is bound to be undermined by the absence of formal global governance structures dealing with: (1) the supervision of large cross-border financial institutions, so-called Globally systemically important financial institutions (G-sifis); (2) the reso-lution of large cross-border financial groups; (3) the extension of global supervisory oversight to the shadow banking sector; and (4) the building of knowledge-based standard-setters for international finance that would closely co-operate and supervise the most effective of the existing soft law bodies, such as the basel committee on banking supervision, on a legally binding basis.

The eurozone debt crisis entered its critical phases after the comple-tion of the manuscript. as a result, it is not given full consideration in the book. a weak and severely under-capitalized banking sector is again at the heart of the problem, making several of the obvious solutions, such as large-scale sovereign debt restructuring, unsustainable. arguably, developments in the eurozone give additional force to one of the central arguments of this book as regards the need for impartial and effective supra-national governance structures to regulate and supervise global markets and especially large cross-border financial institutions, strength-ening the force and effectiveness of ongoing regulatory reforms.

The writing of this book started at the beginning of my study leave in september 2008. a week later lehman brothers collapsed and any mean-ingful writing effort paused for at least two years. in the meanwhile,






Preface xvii

the world of global finance changed forever. The scholarly and policy- making analysis of global markets and of the global financial crisis that has emerged since 2008 has been fragmented but yet in many cases it has been of peerless quality. in addition, the bulk of relevant analysis has been immense and probably beyond the ability of a sole researcher to read, save understand, what was said there. at the same time, reform was taking shape in a number of areas, especially the regulation of systemic risk and ‘too-big-to-fail’ institutions, at rapid pace and at all levels: national, re-gional, international. as a result, keeping up with developments became an impossible task and the idea of dropping the project altogether came to my mind several times. nonetheless, the immense challenges the modern world presents are inextricably tied up with the good workings of global finance, which since 2007–8 seems to have fallen into a state of irremedi-able disrepair. Thus, the desire of joining other (much more influential) voices in offering an analysis and possibly a workable first solution to the problem was one of the reasons that kept me going. My mother’s great ex-ample of fortitude in the face of personal loss and her unfailing support was the second major reason. The third was the encouragement, support and immensely helpful advice i received from very distinguished schol-ars. charles Goodhart has frequently shared his invaluable insights with me and shed light on many areas of global markets and their regulation that looked incomprehensive. This work would have been much poorer without being able to ‘drill’ into his vast well of knowledge in the field of global markets and global finance reform. Joe norton, one of the found-ers of international financial regulation as a distinct academic discipline, proved to be the mentor and friend only the most fortunate ever have in their academic lives. in email after email Joe gave me constructive advice, sense of direction, access to his work and incredible emotional support following the death of my father in March 2010. steven schwarcz, one of the giants of modern financial law, not only was the kindest of hosts during my stay at Duke law school, but also has been a good friend and colleague, who has provided inspiration with his original scholarship and work ethic. eilis ferran, one of the founders of this series, and a scholar of the highest order in the field of corporate and financial law, was both very supportive in the planning stages of this book and a source of rational and constructive advice during the research and writing stages. cambridge University Press editor, kim Hughes with her strict adherence to dead-lines constantly reminded me that this book, like any other, should have a completion date and for everything that comes next there is always the possibility of a second edition. i am immensely grateful to all of them.






Prefacexviii

special thanks must go to sir ross cranston for finding the time to read the manuscript and provide the foreword for this book. i am also grateful for his advice about the timing and contents of this book and his invaluable insights on global financial reform. once again it has been an immense privilege to be able to benefit from discussions with sir William blair on various aspects of this book.

i had immensely informative and constructive discussions on various parts of this book with a number of distinguished scholars and good friends, especially Douglas arner, lawrence baxter, ross buckley and Heracles Polemarchakis. Doug, larry, ross and Heracles repeatedly gave me access to their unpublished work and dedicated hours of email and face to face discussions to our mutual effort to understand the whirlwind developments unfolding in front of our eyes and make (scholarly) sense of them. i am deeply indebted to all of them. similarly i am indebted to my Manchester colleagues, Dora kostakopoulou and William lucy, for similar discussions and much appreciated editorial advice. i have also held very stimulating discussions with colleagues from other Uk uni-versities and especially iain Macneil, Joanna Gray and Dalvinder singh. i am grateful to them for sharing with me their insights and scholarly work. The same applies to eva Hupkes of the fsb for kindly giving me access to her unpublished work.

i would also like to thank all the academics and students that have attended my lectures and seminars on several themes of this book in the past three years at the Universities of oxford, cambridge, Duke, copenhagen and Hong kong. The participants of the conference ‘Greening Humanity’, held in athens at the eugenides foundation in october 2010, and especially my colleagues in Manchester and co-organizers of this conference John Harris and Jon sulston (nobel Prize, Med. sci., 2002), have taught me a great deal about the moral dilemmas facing our modern world and its multi-faceted challenges. Discussions with them and with olMMoG are responsible for planting into my mind one of the central ideas of this book.

in writing this book i have also incurred a number of institutional debts. first, i would like to acknowledge the generous financial support i have received from the Uk’s arts and Humanities research council (aHrc) by means of a study leave research grant. i would also like to thank Manchester law school and its then Head of school andrew sanders for granting me a year-long study leave upon re-joining the law school. i would also like to thank Duke law school and its Dean David levi for hosting me as a Global capital Markets fellow during the






Preface xix

aY 2008-2009. last but not least i would like to thank the production team at cambridge University Press and especially sarah roberts for their great work in turning my manuscript into the book you hold in your hands.

The book considers global financial developments up to 20 July 2011 and discusses regulatory proposals issued until that date with only minor updates for follow ups. furthermore, every effort has been made to state the law as it stood on 30 June 2011.






xx

a b b r e v i a t i o n s

abcP asset backed commercial Paperabs asset backed securitiesaifMD alternative investment fund Managers DirectiveaMH adaptive Markets Hypothesisbcbs basel committee on banking supervisionbHc bank holding companybis bank for international settlementsboe bank of englandcbo collateralized bond obligationscbrG cross-border resolution GroupccP central counterpartycDo collateralized Debt obligationcDs credit Default swapcebs committee of european banking supervisorscesr committee of european securities regulatorscftc commodity futures trading commission (Us)cln credit linked noteclo collateralized loan obligationcoco contingent capital instrumentcra credit rating agencycva credit valuation adjustmenteaD exposure at defaulteba european banking authorityebrD european bank of reconstruction and Developmentecb european central bankeib european investment bankeioPa european insurance and occupational Pension authorityel expected losseMH efficient Market Hypothesisesa european supervisory authorityesfs european system of financial supervisorsesMa european securities Markets authority






List of abbreviations xxi

esrb european systemic risk boardeU european UnioneWs early Warning systemfannie Mae federal national Mortgage associationfatf financial action task force on Money launderingfDic federal Deposit insurance corporationfrb federal reserve board (Us)freDDie Mac federal Home loan Mortgage corporationfsa financial services authority (Uk)fsaP financial sector assessment Programfsb financial stability boardfsD financial sector Developmentfsf financial stability forumfsoc financial stability oversight councilfssa financial sector stability assessmentGats General agreement on trade in servicesGatt General agreement on tariffs and tradeG-20 Group of 20GDP Gross Domestic ProductGfc Global financial crisisGse Government sponsored enterpriseG-sifi Globally systemically important financial institutioniaasb international auditing and assurance boardiais international association of insurance supervisorsiasb international accounting standards boardiascf international accounting standards committee foundationibrD international bank for reconstruction and Developmentifac international federation of accountantsifi international financial institutionsifs international financial standardiif institute of international financeiMf international Monetary fundiosco international organization of securities commissionsirb internal ratings based approachisDa international swaps and Derivatives associationisMa international securities Market associationissb international standard setting bodylcfi large complex financial institutionlcr liquidity coverage ratiolGD loss Given DefaultMbs Mortgage backed securitiesMDGs Millennium Development Goals






List of abbreviationsxxii

MoU Memorandum of Understandingnav net asset valuenifa new international financial architecturensfr net stable funding ratioobse off-balance sheet entityoecD organisation for economic co-operation and Developmentola orderly liquidation authorityotc over the counterPca Prompt corrective actionPD probability of defaultPse Public sector entityrMbs residential Mortgage-backed securitiesrosc reports on the observance of standards and codesrWas risk-weighted assetssDrs special Drawing rightssec securities and exchange commission (Us)sifi systemically important financial institutionsiv special investment vehiclesPe special Purpose entitysPv special Purpose vehicletarP troubled assets relief Programtrn transnational regulatory networktrs total return swapUn United nationsUnctaD United nations conference on trade and DevelopmentUnDP United nations Development ProgrammeWto World trade organization




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