World Bank & International Financial Institutions

World Bank sanctions and debarment can bring significant financial penalties and also result in cross-debarment with other IFIs under certain circumstances. As a result of a 2010 agreement among the African Development Bank, the Asian Development Bank, the EBRD and the IDB, misconduct associated with World Bank-financed projects may result in debarment from projects financed by one or more of these other IFIs.

Importantly, conduct involving violations of World Bank guidelines may indicate violations of other criminal laws, both in the United States and elsewhere, such as the Foreign Corrupt Practices Act and the U.K. Bribery Act. The World Bank and other IFIs involved in development projects have formed closer working relationships with law enforcement, including the Federal Bureau of Investigation. In addition to forming closer ties to law enforcement, the World Bank and other IFIs have increased their expectations that compliance best practices be implemented by companies working on projects involving funds from the World Bank.

Thus, designing a corporate compliance program that effectively identifies, prevents and remediates misconduct is essential for companies that work on World Bank-financed projects. In the event that a company identifies misconduct, it is equally important to investigate the misconduct quickly and, where appropriate, disclose it to the World Bank to prevent the imposition of costly sanctions.

Our lawyers and advisors have wide-ranging experience in representing companies before the World Bank and other IFIs. Our experience with regard to compliance programs, investigations and monitorships includes:

• Provide advice and counsel related to development and implementation of global anticorruption compliance programs.
• Benchmark existing compliance programs against applicable guidelines to proactively identify and remediate gaps.
• Assist companies in automated compliance solutions to implement enhanced compliance capabilities and improve efficiencies.
• Conduct internal investigations of corruption allegations and defending investigations by the World Bank or other IFIs.
• Counsel on and preparing disclosures for relevant IFIs and other government and nongovernmental international regulators.
• Defend companies and employees involved in allegations of criminal misconduct relating to projects involving World Bank or other IFI funds.
• Engagement, as part of the World Bank’s VDP, as the independent compliance monitor responsible for evaluating a company’s compliance programs and submitting recommendations to the company and the World Bank regarding the adequacy of those programs.