Pursuant to Sanctions Board Decision No. 101 issued in Successor Appeal No. 216/249, the Sanctions Board finds that the World Bank's determination that IT-Integrator Limited (the "Appellant") is the successor to Information Computer Systems CJSC, the entity sanctioned pursuant to Sanctions Board Decision No. 71 (2014) and Sanctions Board Decision No. 87 (2016) (the "Sanctioned Firm"), lacks an observable basis. The World Bank thus abused its discretion in making that determination.