The World Bank sanctions system has teeth. Just ask Oxford University Press, Alstom, KBR, and the more than eighty other companies and individuals debarred over the last year for violating the Bank’s Procurement Guidelines and Consultant Guidelines with corruption, fraud, or collusion. Or ask the numerous entities currently under investigation by the Bank’s Integrity Vice Presidency (INT). As one of the small number of U.S. lawyers who focuses on the FCPA but has also investigated and built World Bank cases that have gone before the Sanctions Board (as well as similar entities at other development banks), I have taken great interest in recent developments at the World Bank Sanctions system. If you happen to be serving as a respondent’s attorney before the Sanctions Board, this article offers some things you should know.
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