World Bank Group Sanctions Advocacy

If your business participates in World Bank projects (as a principal contractor or subcontractor/supplier)…know the risks! 

Multilateral development banks such as the World Bank (collectively, the “World Bank Group”) provide financing and professional advising for the purpose of development.  (A list of these entities is found below.)  They can be crucial partners in advancing infrastructure and projects in the developing world.

Conscious of fraud and corruption risk, the World Bank Group enforce strict compliance procedures for their borrowers and their third party contractors.  The World Bank Group also enforces its regulations on investigations and sanctions for non-compliance.  Since 2001, more than 700 firms and individuals have been publicly sanctioned by the World Bank Group ( 

Sanctions are severe and can result in debarment.  Unfortunately, many of the World Bank Group participants are neither aware of the compliance procedures nor cognizant that they should participate in their own defense.  Taking an active role in proceedings is crucial: without an adequate defense, the internal prosecutor becomes both judge and jury and a sanction is all but certain.  Additionally, serious sanctions are eligible for cross-debarment, meaning that a violation will bar the defendant from all other multilateral development banks as well.

To continue being eligible for World Bank Group projects, an entity that is debarred (or conditionally non-debarred) will need to demonstrate adequate remedial measures to improve business governance.  This process can be invasive and may require significant structural and cultural change.  Fortunately, the World Bank provides guidelines on establishing a compliance management system in its Integrity Compliance Guidelines (found at Self-Help Resources).

Do you need a robust defense before the Sanctions Board?  Or do you need strong leadership to demonstrate adequate remediation?  With two decades of global compliance experience, Josh Wallenstein is the attorney of choice for World Bank Group work.  He has successfully served as the Compliance Expert for the World Bank, and would be pleased to discuss advocacy in your matter.

Due in part to their competitive bids and universal presence, companies from the People’s Republic of China seem to be a particular target for sanctions investigations.  The Wallenstein Law Group has partnered with two seasoned attorneys to ensure adequate coverage of Chinese legal needs:

  • Amy Sommers is a US-licensed attorney offering decades of legal and cultural experience both from China residency and with Chinese companies.
  • Qian “Sophie” Ying is a US- and PRC-licensed attorney with extensive experience in Chinese and international legal and compliance matters.

If you need assistance, contact us today!

Multilateral Development Banks
World Bank (WB)
European Investment Bank (EIB)
Islamic Development Bank (IsDB)
Asian Development Bank (ADB)
European Bank for Reconstruction and Development (EBRD)
CAF – Development Bank of Latin America (CAF)
Inter-American Development Bank Group (IDB, IADB)
African Development Bank (AfDB)
New Development Bank (NDB)
Arab Petroleum Investments Corporation (APICORP)
Eastern and Southern African Trade and Development Bank (TDB)

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