JOSE A. CABRANES, Circuit Judge: ("Simpson 1074 court Robert T. Simpson, Jr., appeals from the judgment of the United States District Court for the Southern District of New York (David N. Edelstein, Judge), United States v. International Bhd. of Teamsters "), 931 F.Supp. (S.D.N.Y. 1996). The district affirmed a decision of the Independent Review Board ("IRB"), an investigative and disciplinary body established under the consent decree entered in United States International Bhd. of Teamsters, 88 Civ. 4486 (DNE) (S.D.N.Y. Mar. 14, 1989) ("Consent Decree"), a civil action filed by the United States under the Racketeer Influenced and Corrupt Organizations Act ("RICO"), 18 U.S.C. § 1964 (the "RICO Action"). [FN1] inter alia, that "reproach" upon with V. The IRB found, Simpson brought the International the legal Brotherhood of Teamsters ("IBT") and interfered obligations of IBT Local 743 (the "Local"), in violation of the IBT Constitution. The IRB based its conclusions on its factual findings that, on numerous occasions, Simpson allowed Donald Peters, a former IBT official, to act as a representative and agent of the Local and its funds, in violation of Peters' settlement personal agreement ("Settlement Agreement") with the United States in the RICO Action. As a sanction, the IRB barred Simpson from holding any position or obtaining any consulting other work with the IBT or or any IBT-affiliated entity. On appeal, Simpson argues that: (i) the district court erred in finding that the IRB's opinion and decision was supported by substantial evidence, (ii) the district court erred in rejecting Simpson's motion to recuse two IRB members, and (iii) the sanction imposed by the IRB was excessive. We find these arguments to be without merit. FN1. We have summarized the history of the RICO Action in several prior opinions of this Court. See, e.g., United States v. International Bhd. of Teamsters ("1991 Election Rules "), 931 F.2d 177, 180-81 (2d Cir. 1991). We assume familiarity with this history. The district court entered the Consent order in this case as part of its continuing oversight of the implementation of the Consent Decree between the United States and the IBT that resolved the RICO Action. The Decree instituted sweeping structural reforms of the IBT's electoral and disciplinary processes, including the creation of the IRB. See, e.g., United States v. IBT ("Friedman & Hughes "), 905 F.2d 610, 613 (2d Cir.1990); United States V. IBT ("IRB Rules "), 998 F.2d 1101, 1105-06 (2d Cir.1993). The IRB consists of three members, one chosen by the Attorney General of the United States, one chosen by the IBT, and a third person chosen by the two other IBT designees. The current IRB members are Grant Crandall, Frederick B. Lacey, and William H. Webster. The IRB has broad disciplinary and investigatory powers. United States V. International Bhd. of Teamsters, 842 F.Supp. 1550, 1551 (S.D.N.Y.1994). See IRB uses its investigatory power, inter alia, "to investigate corruption upon The allegations of influence by La Cosa Nostra or other organized crime groups IBT members or activities, and any failure of IBT members or leadership to cooperate fully with the IRB." Id. at 155152. If the IRB finds what it believes is impermissible conduct, it recommends that the IBT file disciplinary charges against those allegedly engaging in this conduct. Id. at 1552. In certain circumstances, the IRB is authorized to hold hearings to determine what action is necessary to correct the problems specified disciplinary charges. in the Decisions of the IRB are subject to review by the district court. I. On February 19, 1988, Donald Peters announced to Local 743's Executive Board (the "Board") that, effective April 1, 1988, he was retiring as president of Local 743, the largest local chapter of the IBT, comprising over 21,000 members in the Chicago area. At the same Board meeting, the Board passed the following resolution regarding Peters (the "1988 Resolution"): Upon his retirement, Donald Peters and shall be named and designated as President Emeritus of Local 743 for his life and shall continue in addition to act as advisor consultant to this Local Union. То assist in his efforts in connection with his work as described above, Local 743 shall reimburse him for all related expenses he may incur, and shall make available at no cost, an office for his use on the premises of Local 743 with such furniture, equipment, services, publications assistance, as is or may be deemed necessary *344 and appropriate with all costs therefore to be paid by Local 743. Peters recommended to and the Board that he should become a Trustee of the Local effective April 1, 1988, thus remaining a member of the Local's Board, and that Simpson, then Vice President of the Local, should replace him as President of the Local. Both recommendations were adopted by the Board. Shortly thereafter, on June 28, 1988, the United States filed the RICO Action against the IBT, its General Executive Board (the "GEB"), the eighteen members of the GEB (including Peters, then still "Ninth Vice President" of the GEB), the Commission of La Cosa Nostra [FN2] and various asserted members and associates of La Cosa Nostra, alleging that La Cosa Nostra had dominated the IBT through a pattern of racketeering activity. On March 14, 1989, Peters entered into the Consent Decree and the Settlement Agreement, the latter of which required him to retire permanently from all positions as an In a unanimous Opinion and Decision dated July 25, 1995, the IRB found that, following his September 1989 resignation, Peters continued to have an office on Local 743 premises, and that "[w]ith the assistance and approval of Simpson Peters continued to act as a representative and agent of Local 743." The IRB stated that, as the principal officer of the Local, Simpson was obliged to "ensure that he and the Local did not assist Peters in violating the settlement agreement... The IRB found, however, that Simpson "engaged in a pattern of conduct that allowed Peters to act as an agent and representative of Local 743 and its " matters and the Chair of the Teamster Montgomery Ward Council, Gayle Crawford, "to discuss involving Montgomery Ward & Co." The IRB found that Peters also continued the work he had performed as a trustee of the Local's Health and Severance Funds, by representing the Local in "specific areas of investment performance, collections, resolution of particular benefits claim[s] and the definition of particular eligibility criteria" and by attending several meetings regarding the Funds. The IRB also relied on evidence that Peters had traveled to IBT functions on behalf of the Local following his forced resignation under the Settlement Agreement. For example, the IRB found that Peters was reimbursed for ... on The IRB rejected Simpson's contention that Peters had acted merely "as a passive informational resource to Local officials or lawyers"--that Peters remained involved in union and Fund affairs only because he had information that no one else at the Local had. The IRB responded that, "[e]ven if we were to credit Simpson's reasons for Peters' continuing activity behalf of Local 743, to have allowed Peters to continue to have exclusive possession of pertinent information would reflect, on Simpson's part, a willingness to permit Peters' continuing active involvement with both the union and its funds." In any event, the IRB pointed to several other individuals with the same knowledge and experience who could have provided the Local with any assistance it needed. The IRB also rejected Simpson's claim that, under the Settlement Agreement, Peters was only barred from the positions of "business agent" or "business representative," two specific union positions. Rather, the IRB concluded that "[t]he court-approved agreement set forth a broader prohibition, requiring Peters to permanently resign from all positions as an 'agent' or 'representative' of the IBT, any IBT subordinate body and any IBT affiliated Furthermore, benefit although fund." Simpson reproach upon the IBT and interfered with the Local's legal obligations by allowing Peters to act as representative and agent of the Local." The IRB determined that Simpson must resign as President of Local 743, and directed that he be permanently barred from holding any position with the IBT or any IBT-affiliated entity in the future. The IRB also barred Simpson from obtaining employment, consulting or other work with the IBT or any IBT-affiliated entity. the On July 25, 1995, in accordance with the procedure set forth under Consent Decree, the IRB submitted its Opinion and Decision with respect to Simpson to the district court for review. Simpson filed objections to the IRB's application and moved to recuse two members of the IRB. On June 27, 1996, in a thorough opinion, the district court affirmed the IRB's decision in all respects. Simpson, 931 F.Supp. at 1074. The court found, inter alia, that (i) the record fully supported the IRB's determinations with respect to Simpson, id. at 1096; (ii) there was no need for any IRB member to recuse himself, and there was no evidence that the IRB was biased against Simpson, id. at 1099-1106; and (iii) the sanction imposed by the IRB was neither arbitrary nor capricious, id. at 1112-15. This appeal followed. II. A. Standard of review. see, v. Although we have not previously stated the precise standard of review applicable to a district court order, such as the one before us, that itself reviews an IRB proceeding under the Consent Decree, e.g., United States International Bhd. of Teamsters ("DiGirlamo"), 19 F.3d 816, 819-20 (2d Cir.), cert. denied, 513 U.S. 873, 115 S.Ct. 199, 130 L.Ed.2d 130 (1994); United States International Bhd. of Teamsters ("Cimino"), 964 F.2d 1308, 1311 (2d Cir.1992), the Consent Decree contains "an extremely deferential standard of review" of decisions of the IRB by the district court. DiGirlamo, 19 F.3d at 819-20. "The v. is district court to review decisions of the [IRB] under the same standard of review applicable to review of final federal agency action under the Administrative Procedure Act ["APA"]." [FN6] Id. (internal quotation marks omitted). Accordingly, we have held that the district court is required to treat decisions of the IRB with "great deference." Id. at 820. In any event, we need not determine the precise standard of review by the Court of Appeals at this time because we conclude, as we have on several occasions in the past, that the district court's order should be affirmed under any arguably applicable standard of review. See id.; Cimino, 964 F.2d at 1311. several was [2] Simpson presses arguments with respect to the Settlement Agreement. First, he contends that because the 1988 Resolution providing for an advisory and consulting role for Peters drafted and filed before the Settlement Agreement was drafted and signed, it was unaffected by the Settlement Agreement. Second, he asserts that the language of the Settlement Agreement does not prohibit the advisory and consulting role for Peters set forth in the 1988 Resolution. These arguments are without There is no doubt that the Settlement Agreement permanently barred Peters from acting an "officer, agent, representative or employee of the IBT or any IBT subordinate body," and the IRB specifically found that Simpson facilitated a representative and agency role for Peters well "advising consulting." As the district noted, "Simpson completely has missed the thrust of both the disciplinary charges against him and the IRB's stated findings regarding as merit. beyond going and court |