In the continuing COVID-19 pandemic, many companies face new COVID-19-related compliance risks, including increased anti-corruption scrutiny of pandemic relief efforts financed by multilateral development banks (MDBs or “Banks”). Understandably, anti-corruption enforcement by the U.S. Department of Justice for violations of the Foreign Corrupt Practices Act (FCPA) typically receives the most attention in the U.S. context. However, given the billions of dollars made available by MDBs such as the World Bank and Africa Development Bank (AfDB) for pandemic containment and recovery efforts over the last 18 months or so, private parties who receive this funding and their contractors should anticipate an upsurge in anti-corruption enforcement by MDBs and safeguard against this risk by reviewing and enhancing their compliance programs.