More than a year after lodging our complaint against the banks, the Belgian and Luxembourg NCPs handed over their draft initial assessments of the complaint to Open Secrets, CALS and the banks. The initial assessment is an assessment of whether there is sufficient evidence to investigate the complaint further. This was not a decision about the merits or substance of the complaint, but merely about whether there is bona fide (‘good faith’ / an indication of) evidence that suggests there is merit to the complaint. The initial assessment was meant to happen within 3 months of the complaint being lodged. A year later, the NCPs provided a scant draft initial assessment for our input. In their draft assessments, the NCPs ignored the bulk of the evidence presented to them, and dismissed the rest as ‘dated’ or old (that the conduct within which apartheid was situated happened too long ago). They even went so far as to invent defences for the banks. Open Secrets + CALS provided the NCPs with an extensive & thorough response, after which the NCPs handed us their final initial assessment. Not a single word had changed between the draft initial assessment & the final; in other words, the NCPs ignored our input entirely.