CAT/OP/BRA/2 information about the prison’s closure, including the date on which this has taken or will take place, and further information about the facilities to which current detainees are relocated. If the authorities intend to continue refurbishing the prison once it is empty, the SPT requests details of the specific refurbishment work that is planned, and timeframes for its completion and reopening to accept detainees. 14. In its Preliminary Observations the SPT stated its serious concerns about the risk of reprisals against persons it interviewed, as well as the lack of appropriate control and safeguards against reprisals, (see Report paras. 59-62). The SPT remains very concerned about this issue, which it considers to be both significant and ongoing. Due to the priority of the matter, the SPT draws the State’s attention to its comments on the matter below and requests that steps be taken to implement its recommendations in this relation (See below, paras. 47-51). 15. The SPT further recommends that independent bodies of oversight, such as representatives from the Ombudsman’s Office, the judiciary, civil society and (if applicable) the local preventive mechanism should visit the sites to which detainees have been transferred in order to provide an accurate reflection of the standards of treatment and conditions in these alternative facilities. The SPT requests details of any such arrangements and visits that have been made. IV. Implementation A. Complexity of Federal System 16. As indicated above, the SPT is very concerned by the heavy emphasis Brazil has placed in its Reply on the complexity of its federal system, and in particular its emphasis on strict formalism between the powers and responsibilities of different state entities. The SPT recognizes that Brazil’s federal structure is indeed, complex. However, the SPT is concerned that this is being relied upon to excuse many of the issues, - including the deplorable conditions and treatment of very large numbers of detainees, - that are highlighted in the SPT’s visit Report. 17. The SPT must stress that the complexity of Brazil’s federal system can in no way justify non-compliance with its international obligations. The SPT further reminds the State, that it is the Federal State of Brazil, as a complete and unified entity, that is under direct obligation to comply with its obligations under OPCAT, as is indeed the case with all other treaties to which Brazil is a high contracting party. 18. The SPT further reminds the Brazilian authorities of the ILC Articles on Responsibility of States for Internationally Wrongful Acts, Article 4, which make it clear that, in international law, (ie. relevant to OPCAT), it is the Central State authorities that bear the responsibility for the actions of its organs, including those that fall under the jurisdiction of localized federal entities. It is neither appropriate nor acceptable for the Central Authorities to rely on the complexity of Brazil’s federal system to explain its non-compliance with its international obligations. Rather it remains the Central authorities’ responsibility to ensure implementation and compliance at all levels across the State. The SPT hopes that the Brazilian authorities will take these points on board and, in the spirit of cooperation which the SPT and indeed the OPCAT intend, take steps to address this matter in the light of recommendations put forward in the present Response. 19. On this point, the SPT requests to know; 5