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Sanctions System Annual Report 2022✭

October 14, 2022

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Sanctions System Annual Report for fiscal year 2022

How to Report Fraud and Corruption & Contact Information

inside cover

Message from the World Bank Group President

Fiscal Year 2022 Summary Results

The Sanctions System: An Integral Part of the World Bank Group’s Anticorruption Efforts

The Integrity Vice Presidency

Introduction by Mouhamadou Diagne, Integrity Vice President

Who We Are

What We Do

Detect: INT’s Investigations

Deter: Sanctions, Referrals, and Integrity Compliance

Prevent: Prevention, Risk & Knowledge

The Office of Suspension and Debarment

Introduction by Jamieson A. Smith, Chief Suspension and Debarment Officer

Who We Are

What We Do

OSD Case Summary

Symposium on Supranational Responses to Corruption

Other Events and Outreach

The Global Suspension & Debarment Directory

Sanctions Imposed by the SDO Pursuant to Notices of Uncontested Sanctions Proceedings

The WBG Sanctions Board

Introduction by Giuliana Dunham Irving, Executive Secretary to the WBG Sanctions Board

Who We Are

What We Do

Knowledge Sharing and Engagement with Stakeholders

Summary of Precedent in FY22

Annexes: Fiscal Year 2022 Sanctions System Data

SANCTIONS SYSTEM ANNUAL REPORT • FISCAL YEAR 2022

« i

FIGURES
FIGURE 1: Offices of the WBG Sanctions System

FIGURE 2: INT Management Structure

FIGURE 3: Regional Breakdown of External Investigations Started in FY22

FIGURE 4: Duration and Regional Breakdown of Active External Investigations at the end of FY22

FIGURE 5: Duration and Regional Breakdown of Completed External Investigations in FY22

FIGURE 6: Subjects of Internal Investigations in FY22

FIGURE 7: Outcomes of INT’s Closed Internal Investigations in FY22

FIGURE 8: Percentage of cases & settlements reviewed by OSD by type of sanctionable practice*

FIGURE 9: Regional Origin of Respondents Sanctioned by the SDO and the WBG Sanctions

Board (110 Cases) (FY18–FY22)

FIGURE 10: Regional Origin of Respondents Sanctioned by Settlement (103 Cases)

(FY18–FY22)

FIGURE 11: Location of Misconduct Sanctioned by the SDO and the WBG Sanctions Board

(161 Sanctions (FY18–FY22)

FIGURE 12: Location of Misconduct Sanctioned via Settlement (126 Sanctions) (FY18–FY22)

FIGURE 13: SDO Application of Aggravating Factors (472 Respondents) (12/16/10–6/30/22)

FIGURE 14: SDO Application of Mitigating Factors from WBG Sanctioning Guidelines (472

Respondents) (12/6/10–6/30/22)

FIGURE 15: Trend in the Type of Misconduct Alleged in Cases Contested to the Sanctions

Board (by Case) (FY18–FY22)

FIGURE 16: Type of Sanctions Imposed on the Respondents by the Sanctions Board (FY18–FY22)

FIGURE 17: Number of Decisions Issued by the Sanctions Board (FY18–FY22)

ii » SANCTIONS SYSTEM ANNUAL REPORT • FISCAL YEAR 2022

Abbreviations and Acronyms

ADB

Asian Development Bank

IDB

Inter-American Development Bank

AfDB

African Development Bank

IFC

International Finance Corporation

AFE

Africa Eastern and Southern Region

INT

Integrity Vice Presidency

AFW

Africa Western and Central Region

LCR

Latin America and the Caribbean Region

CDU

Complaints Development Unit

MDB

multilateral development bank

Curriculum Vitae

MIGA

Multilateral Investment Guarantee Agency

EAP

East Asia and Pacific Region

MNA

Middle East and North Africa Region

EBC

Ethics and Business Conduct Department

MOU

Memorandum of Understanding

EBRD

European Bank for Reconstruction and
Development

OECD

Organisation for Economic Co-operation and
Development

ECA

Europe and Central Asia Region

OSD

Office of Suspension and Debarment

Evaluation and Suspension Officer

PRKM

Prevention, Risk, & Knowledge Management

FIR

Final Investigation Report

PSU

Preventive Services Unit

FSU

Forensic Audit and Digital Forensics Unit

SAR

South Asia Region

GlobE
Network

UNODC’s Global Operational Network of
Anti-Corruption Law Enforcement Authorities

SDO

World Bank Chief Suspension and Debarment
Officer

HRDVP

WBG Vice President for Human Resources

SPADR

IBRD

International Bank for Reconstruction and
Development

Director of Strategy, Performance and
Administration

StAR

Stolen Assets Recovery Initiative

ICO

Integrity Compliance Office

UNODC

United Nations Office on Drugs and Crime

IDA

International Development Association

WBG

World Bank Group

SANCTIONS SYSTEM ANNUAL REPORT • FISCAL YEAR 2022

« iii

Message from the World Bank Group President

The world today is facing dan-

are used in a transparent and accountable manner and only

gerous, overlapping crises that

for their intended purposes. We must be continually vigilant

are hitting the poor and vul-

against corruption in the projects supported by the Bank

nerable and worsening global

Group. Corruption has a pernicious effect on development

inequality. High inflation, war in

and poses significant obstacles to our work to alleviate

Ukraine, large macroeconomic

extreme poverty and boost shared prosperity. Among them,

imbalances, and shortages of

it diverts scarce resources from achieving the projects’

energy, fertilizer, and food have

objectives, robbing the benefits of development from the

caused the sharpest global eco-

people who need them most; it increases costs for the most

nomic downturn in 80 years,

vulnerable while reducing their access to services—including

compounding the death tolls, economic shutdowns, and

health, education, and justice; and it undermines the public’s

school closures of the COVID-19 pandemic. Low- and middle-

trust in institutions, thereby weakening governance and rule

income countries now face surging prices for natural gas

of law and increasing fragility.

and fertilizer and the worst food crisis in a decade, as they
work to achieve progress on long-term development needs—
including clean water, electricity access, reading skills, quality

At a moment when every available resource must be
deployed for maximum impact, these ill effects of corruption

infrastructure, and climate-related investments.

can be especially damaging. For this reason, it is important

The World Bank Group is responding to these challenges

which plays a significant part in our institution’s efforts to

with speed, clarity, scale, and impact. We’ve committed two

maintain oversight and accountability for the financing we

consecutive surges of financing, analytical work, advocacy,

provide. The offices that comprise the sanctions system—

and policy advice to support people, preserve jobs, and

the Integrity Vice Presidency (INT), the Office of Suspension

restore growth—first, $150 billion in response to the COVID-

and Debarment (OSD), and the Sanctions Board and its

19 pandemic, and now a 15-month $170 billion response to

Secretariat (SBS)—work together to send a clear message:

the food crisis as well as the war in Ukraine and its spillover

corruption has no place in development.

effects. Since the start of the pandemic through fiscal 2022,
the Bank Group has provided over $14 billion to help more
than 100 countries respond to the health impacts of COVID-

to recognize the role of the Bank Group’s sanction system,

The teams across the Bank Group’s sanctions system support our institution by working to impartially investigate

19 and vaccinate their people.

allegations of corruption within our operations, and to trans-

While our institution continues to provide historic levels of

have engaged in such misconduct. Beyond this, they also

support around the world, it remains critical that these funds

support the rehabilitation of sanctioned entities to improve

iv » SANCTIONS SYSTEM ANNUAL REPORT • FISCAL YEAR 2022

parently evaluate and sanction firms and individuals who

Corruption has a pernicious effect on development and poses
significant obstacles to our work to alleviate extreme poverty and
boost shared prosperity. . . . It diverts scarce resources from
achieving the projects’ objectives, robbing the benefits of
development from the people who need them most.

their business standards, thereby encouraging a cleaner pri-

new and closed 31 existing external investigations and sub-

vate sector in the countries where we operate. In addition,

mitted 18 sanctions cases and 15 settlements for review and

they provide knowledge and guidance based on more than

adjudication. As a result of some of these and earlier sub-

two decades of investigations into corruption to better mit-

mitted cases and settlements, the Bank Group debarred or

igate and manage corruption risks within the Bank Group’s

otherwise sanctioned 35 firms and individuals. In addition,

current portfolio of operations.

the Bank Group’s Integrity Compliance Office determined

Moreover, through the engagements by the offices of
the sanctions system, our institution has continued to
strengthen the partnerships that extend its anticorruption

that 22 entities had met their conditions for release from
sanction, making them eligible to again participate in projects financed by the Bank Group.

impact beyond our own development projects. Through our

OSD continued implementing its mandate of providing a fair

harmonized sanctioning efforts with our peer multilateral

and efficient first-tier review of all Bank sanctions cases, as

development banks (MDBs), we collectively ensure that

well as an assessment of all related settlement agreements

bad actors are barred from misusing MDB funds. Through

and cross-debarments with other MDBs. And the Sanctions

collaborations with national, regional, and global anticor-

Board continued to ensure the prompt and fair disposition

ruption agencies, our teams help to build networks that are

of all contested cases by transitioning to a hybrid operating

responsive to corruption risks. And through participation

model—holding its first in-person hearing and deliberations

in multilateral fora engaged in addressing fraud and cor-

since the start of the pandemic.

ruption, we can help to influence and bolster international
actions against misconduct at the highest levels.

Looking ahead, the Bank Group will continue to provide its

Achieving results in the fight against corruption requires that

trust that, likewise, the Bank Group’s sanctions system will

our teams engage in all these areas and more.

continue to carry out its anticorruption mission in kind. I

As this annual report describes, our sanctions system did
not falter in carrying out its important responsibilities this
year. INT maintained its vigilance over the Bank Group’s
financing, resuming critical on-the-ground investigations,
supporting operational staff in identifying and managing
risks, and redoubling efforts to engage with companies to
strengthen business compliance standards. INT opened 48

support to countries facing unprecedented challenges. I

commend the efforts of the professional teams across the
Bank Group’s sanctions system, as well as the people with
the courage and character to bring forward allegations of
fraud and corruption they witness. Together, we endeavor
to bring greater integrity, transparency, and accountability
to the development work that is of critical value to so many
places and people around the world.
David R. Malpass
President of the World Bank Group

SANCTIONS SYSTEM ANNUAL REPORT • FISCAL YEAR 2022

« 1

Fiscal Year 2022 Summary Results
This annual report covers fiscal year 2022—from July 1, 2021, to June 30, 2022—and was prepared by the
offices of the World Bank Group’s (WBG1) sanctions system, which comprises the Integrity Vice Presidency
(INT), the Office of Suspension and Debarment (OSD), and the Sanctions Board and its Secretariat.

In Fiscal Year 2022 (FY22):

4 fully-reasoned decisions resolving 4 contested sanctions cases against 6

• The Sanctions Board published

• INT launched a Strategy Update following a robust consultation process that, while maintaining focus on INT’s
core anticorruption mandate, will allow INT to achieve

respondents. The Sanctions Board convened a virtual
hearing in 1 of those cases.

greater impact by enhancing its risk-based approach

Beyond the core mandate of the WBG’s sanctions system,

to investigations, strengthening the delivery of timely

in FY22:

and actionable prevention support, and developing its
knowledge management processes and products.

3,380 complaint submissions, opened
330 new external preliminary investigations, and
started 48 new and closed 31 existing external investigations. INT submitted 18 sanctions cases, and 12
settlements to OSD. An additional 3 settlements were

• INT received

submitted to the IFC Evaluation Officer for review.

28 cases of alleged fraud and corruption
involving WBG staff and 19 cases involving corporate

• INT pursued

vendors. INT substantiated misconduct allegations in

1 WBG staff case and in 3 corporate vendor cases.
• INT leveraged closer collaboration between its prevention, complaints intake, forensic and digital audits,
and data analysis teams to enable its more risk-based
approach to action on complaints, case prioritization,

33 notices

and proactive risk identification, and it developed

to newly sanctioned parties on their conditions for

new business processes and digital tools in

release from sanction and engaged with 81 sanctioned

support of these efforts.

• The Integrity Compliance Office (ICO) sent

parties towards meeting their conditions for release.
In addition, the ICO determined that

22 entities had

met their conditions for release from sanction and that

1 entity had met the conditions for the conversion of
their debarments with conditional release to conditional
non-debarments.

• In April 2022, OSD led the organization of a two-day
symposium on Supranational Responses to Corruption
in Vienna, Austria, based on a call for papers addressing current and prospective anticorruption efforts at
the supranational level. The event provided a valuable
opportunity to raise awareness of the WBG sanctions

• OSD reviewed 15 cases and 12 settlements, temporarily

system, connect with and learn from a diverse range of

suspended 14 firms and 6 individuals, and sanctioned

relevant stakeholders, and expand the WBG sanctions

11 respondents via uncontested determinations.

system’s network at a global level in pursuit of varied
efforts against corruption.

2 » SANCTIONS SYSTEM ANNUAL REPORT • FISCAL YEAR 2022

• OSD organized internal and external events to discuss

• The Sanctions Board Secretariat continued to engage

the recently launched Global Suspension & Debarment

with global stakeholders, including by launching

Directory and the use of exclusion as an integrity tool. To

its inaugural newsletter, participating in conferences

further raise awareness of the WBG’s sanctions system,

and workshops on sanctions matters with other MDBs,

the SDO participated in an interview series regarding the

co-coordinating a graduate course on anticorruption

sanctions and debarment regimes at various multilat-

issues in public procurement, and sharing knowledge

eral development banks.

through a program established by the International

• The Sanctions Board Secretariat authored timely

Chamber of Commerce (ICC).

thought pieces that were published on a widely read

The staff across the WBG sanctions system bring diverse

international forum for commentary on anticorruption.

experiences, skills, and backgrounds that reflect the shared

In one piece, the Secretariat discussed the Sanctions

commitment to principles of diversity, equity, and inclusion

Board’s nuanced and predictable approach to selecting

by the offices of the sanctions system. Including the Sanc-

proportionate sanctions. In another piece, the Secretar-

tions Board members, staff across the sanctions system

iat discussed how the Sanctions Board has endeavored

come from

to be agile and adaptive in reviewing and resolving sanc-

below).

44 countries spanning the world (see map

tions cases.

SANCTIONS SYSTEM ANNUAL REPORT • FISCAL YEAR 2022

« 3

The Sanctions System
An Integral Part of the World Bank Group’s Anticorruption Efforts

•
Corruption undermines development objectives, interferes
with the WBG’s fiduciary responsibility, and damages the
reputation of the WBG and its clients. As such, the WBG
takes seriously all allegations of fraud and corruption in
the projects it finances. The sanctions system is a key
component of the WBG’s anticorruption efforts. It ensures
that fraud and corruption impacting WBG operations are
addressed efficiently and fairly for the benefit of the member
countries, and that a strong deterrence message is complemented with a focus on prevention and integrity compliance
programs.

How the WBG Sanctions System Works
The WBG sanctions system addresses allegations of fraud,
corruption, collusion, coercion, and obstruction (collectively
known as the “WBG sanctionable practices”) by firms and
individuals involved in WBG operations in three stages: (i)
investigating whether there is sufficient evidence of the allegations to seek sanctions; (ii) adjudicating whether there
is sufficient evidence to sanction the firm or individual and
what the proper sanction should be; and (iii) engaging with
firms and individuals sanctioned with integrity compliance
conditions to assist them and ultimately determine whether

The WBG’s sanctions system is one aspect of the inter-in-

they have satisfied the conditions imposed for their release

stitutional approach to anticorruption that encompasses

from sanction.

external and internal activities across the WBG to confront
corruption at the project, country, and global levels. These
include external activities such as efforts to detect, diag-

Investigation

nose, and measure fraud and corruption; to support national

The Integrity Vice Presidency (INT) opens new investigations

anticorruption strategies, policies, and practices; and to help

based on those allegations for which a preliminary review

design oversight and accountability mechanisms to prevent

indicates that a full investigation is warranted. When INT

corruption, as well as internal efforts to prevent and mitigate

completes an investigation and determines it has found cred-

integrity risks in operations.

ible and sufficient evidence of sanctionable conduct, INT can

seek sanctions against the firms and individuals involved by
either submitting a sanctions case to the first tier of review in
the sanctions system, or by negotiating a settlement.
FIGURE 1: Offices of the WBG Sanctions System

Investigative

Integrity Vice
Presidency

Adjudicative
Chief Suspension &
Debarment Officer
/ Evaluation &
Suspension Officers

Compliance
Sanctions Board
Integrity Compliance
Office

Uncontested sanctions
& Settlements

Note: Investigations into WBG staff and corporate vendors are adjudicated outside the sanctions system (see pg. 14).

4 || SANCTIONS SYSTEM ANNUAL REPORT • FISCAL YEAR 2021

What are the WBG Sanctionable Practices?
› A corrupt practice is the offering, giving, receiving, or soliciting, directly or indirectly, of anything of value to
influence improperly the actions of another party.
› A fraudulent practice is any act or omission, including a misrepresentation, that knowingly or recklessly misleads, or attempts to mislead, a party to obtain a financial or other benefit or to avoid an obligation.
› A coercive practice is impairing or harming, or threatening to impair or harm, directly or indirectly, any party
or the property of the party to influence improperly the actions of a party.
› A collusive practice is an arrangement between two or more parties designed to achieve an improper purpose,
including influencing improperly the actions of another party.
› An obstructive practice is (a) deliberately destroying, falsifying, altering, or concealing evidence material to
an investigation or making false statements to investigators in order to materially impede a WBG investigation
into allegations of a corrupt, fraudulent, coercive or collusive practice; and/or threatening, harassing or intimidating any party to prevent it from disclosing its knowledge of matters relevant to an investigation or from
pursuing the investigation, or (b) acts intended to materially impede the exercise of the WBG’s contractual
rights of inspection and audit.
Source: Guidelines on Preventing and Combating Fraud and Corruption in Projects Financed by IBRD Loans and IDA Credits and Grants
(revised as of July 1, 2016).

Adjudication
First Tier of Review. At this stage, a first-tier review officer—the Chief Suspension and Debarment Officer (SDO)
for cases that involve public sector IBRD/IDA financing,
or the relevant Evaluation and Suspension Officer (EOs)
for cases relating to IFC, MIGA, and IBRD/IDA Guarantees
and Carbon Finance Operations—assesses the evidence
presented by INT. If the evidence is sufficient, the first-tier
officer will issue a formal notice to the accused respondent,
recommend a sanction, and if the recommended sanc-

for all sanctions cases involving IBRD, IDA, IFC, or MIGA projects, financing, and guarantees. A case reaches this stage if
the respondent chooses to contest liability or the sanction
recommended by any of the first-tier review officers. The
Sanctions Board reviews cases de novo, without reexamining decisions made at the first tier. The Sanctions Board
considers the entire case record and affords the parties an
opportunity to make any additional arguments, furnish new
evidence, and be heard at a hearing if one is so convened.
Sanctions Board decisions are final and unappealable.

tion includes a minimum period of debarment of at least 6
months, will immediately suspend the respondent from eligibility to engage in WBG operations until the conclusion of
sanctions proceedings. The first-tier officer also considers
INT requests for early temporary suspensions, reviews proposed settlement agreements, and imposes sanctions on
respondents that do not contest their case to the Sanctions
Board. In FY22, all sanctions cases submitted by INT were
submitted to the SDO; three of the fifteen settlements were
submitted to the EO for IFC.3

Integrity Compliance
Most entities are sanctioned with integrity compliance conditions that must be met before they can be released from
the WBG sanction. To demonstrate this, they must engage
with the WBG Integrity Compliance Office, which works with
sanctioned entities to help explain the integrity compliance
conditions, recommend enhancements to their internal
controls to best satisfy those conditions, and monitor their
progress toward meeting the conditions. This engagement

Second Tier of Review. The WBG Sanctions Board is an inde-

culminates with the WBG Integrity Compliance Officer

pendent body comprising seven individual members who are

determining whether the conditions have been met for the

entirely external to the WBG. It is the second tier of review

entities’ release from the WBG sanction.

THE SANCTIONS SYSTEM

|| 5

INT delivered on its mandate to detect, deter,
and prevent fraud and corruption in the Bank’s
operations in ways that will have a positive impact
not only for the institution, but also for broader
global anticorruption efforts as well.

6 » SANCTIONS SYSTEM ANNUAL REPORT • FISCAL YEAR 2022

The Integrity Vice Presidency
Supporting the WBG’s anticorruption agenda through investigations into fraud
and corruption, strengthening integrity compliance, and providing insights
into integrity risk prevention.

Introduction by
Mouhamadou Diagne,
Integrity Vice President

While we can point to many notable achievements in INT’s
past, we are not resting on our laurels. In the spirit of continuous improvement and looking toward the future, this year
INT has forged ahead on multiple fronts that will guide and

challenges

shape our next decade. Following extensive internal assess-

over the past fiscal year, the

ments, external reviews, and consultations with our key

World Bank Group’s Integrity Vice

stakeholders, we have taken an in-depth look at and updated

Presidency (INT) continued to

our strategic priorities. Building on an already solid foun-

successfully support the Bank’s

dation and maintaining our core investigative mandate, but

development mission through its anticorruption work. As

with a view to delivering even greater institutional impact,

this annual report highlights, INT delivered on its mandate to

INT will focus on enhancing our risk-based approach to

detect, deter, and prevent fraud and corruption in the Bank’s

investigations and more proactive identification of integrity

operations in ways that will have a positive impact not only

risks, strengthening the delivery of our prevention support

for the institution, but also for broader global anticorruption

to Operations, and developing a more systematic approach

efforts as well.

for sharing INT’s extensive body of anticorruption knowl-

Despite

persistent

In many ways, these successes reflect INT’s continuing
evolution and our efforts to build on the foundations of
our past. This year, INT marked its 20th anniversary as an
independent oversight unit for the World Bank Group. Over

edge. We expect these refined priorities will position INT
to support the World Bank Group even more effectively in
addressing integrity risks that often remain a major threat to
the achievement of our developmental mandate.

these first two decades, INT has grown from a relatively

We have also pursued internal initiatives to strengthen our

small department to a professionalized office that operates

operational processes and to enhance our delivery. Notably,

as one part of a mature sanctions system and stands as

we have made strides in improving the collaboration across

an anticorruption leader among multilateral institutions.

INT to ensure that we are working as an effective and coor-

Along the way, we have strengthened our ability to investi-

dinated whole, we are refining our results metrics to better

gate fraud and corruption allegations, built our capacity to

measure INT’s impact and hold ourselves to account, and

offer preventive guidance and support for the Bank’s devel-

we’re continuing to build the positive and enabling work

opment operations, and advanced our engagements with

environment to enable our staff to deliver to their fullest

the private sector to promote integrity compliance stan-

potential. In addition, this year we engaged with a wide

dards around the world.

range of partners on multiple anticorruption fronts—from
working across the World Bank Group’s sanctions system to

THE INTEGRITY VICE PRESIDENCY

« 7

enhance our sanctions guidelines; to collaborating with the

too will continue to adapt and advance our work to meet the

Bank’s Governance Global Practice to support an update

new challenges we face.

to the institution’s anticorruption priorities; to harmonizing
our principles and practices with our peers among the multilateral development banks; to sharing our insights to help

The dedicated staff across INT is committed to fighting
corruption every day in support of the World Bank Group’s

advance the global anticorruption agenda.

development mission. The impact reflected in this annual

At all of these levels, the relevance of and urgency for robust

the work that they do. Likewise, we recognize the key sup-

and proactive anticorruption efforts is ever more apparent.

port we receive from colleagues and stakeholders across the

In the context of the current global crises, the World Bank

World Bank Group, as well as the enduring collaboration we

Group has recognized a need to increase its available lending

have with our many external partners.

report is the result of their efforts, and I commend them for

support to countries to historic levels. It is therefore critical
for INT to not only remain attentive to current integrity risks,
but to continue to strengthen our capacities, develop new
tools, and do what we must to keep ahead of corrupt actors.

Together with our partners, INT’s efforts to fight fraud and
corruption will continue to make a positive impact in today’s
complex and challenging world.

As the context in which we operate continues to evolve, INT

Mouhamadou Diagne
Integrity Vice President

Who We Are
The Integrity Vice Presidency (INT) is an independent unit

them, they consist of investigators, lawyers, forensic

within the WBG that works to detect, deter, and prevent

accountants, economists, risk specialists, data scientists,

fraud and corruption in WBG-financed operations and by

and information system specialists. As of the end of FY22,

WBG staff and corporate vendors.

INT had 76 full-time staff, along with 33 consultants, sec-

INT’s staff consists of a global cadre of professionals who

ondees, and interns.

are dedicated to the unit’s anticorruption mission. Among

INT Staff At-A-Glance

FROM

STAFF

COUNTRIES

8 » SANCTIONS SYSTEM ANNUAL REPORT • FISCAL YEAR 2022

SPEAKING

LANGUAGES

58%
FEMALE

42%
MALE

INT Staff Profiles

Scholastica Muriithi, Senior Litigation Specialist
Scholastica Muriithi is one of the senior litigators in INT. In this capacity, she advises on
legal strategy during investigations and conducts litigation of cases of fraud and corruption affecting World Bank-financed projects. Her work includes leading negotiations with
firms and individuals resulting in amicable resolution of cases through settlement agreements. She is also the Memoranda of Understanding (MOUs) focal point for INT. Prior to
joining INT, Schola had a long career in anticorruption in Kenya and Eastern Africa.
You help oversee the MOUs that INT has
with other organizations. What do these
partnership frameworks help facilitate?
Each MOU is a unique opportunity to clarify and
strengthen working relationships between INT and
our partner organizations. They define how our offices
engage with one another and how we might share our
respective experience and expertise for mutual benefit. MOUs provide an important framework for sharing
evidence and information with our partners, including
investigative offices of international organizations
and national law enforcement authorities. They bolster the formal relationships that we can draw upon to
ensure that INT’s investigations can effectively reach
all regions and countries where the World Bank Group
operates.

Why are INT’s partnerships so important for its overall anticorruption impact?
The increasingly international and cross-border nature of corruption has made collaboration with our partners very important.
The ability to share and exchange actionable information with our
partners results in timely and cost-effective investigations. This
has positively impacted global efforts of fighting corruption and
deterred corruption in Bank projects. MOUs provide INT and our
partners the ability to participate in each other’s activities, share
knowledge, experiences, and insights, and to better understand
local contexts and tap into local networks of anticorruption actors.
These factors increase the value of maintaining a strong, global
network of partnerships and strengthen the Bank’s ability to ensure
that its funds are used for the intended purposes. By working with
each other, we leverage collective strengths, improve our effectiveness, and increase our overall impact.

Krishna Kesari, Data Scientist
Krishna Kesari leads the technical work of INT’s Data Lab. He brings experience in the private,
nonprofit, government, and international development sectors and an extensive background
developing data-driven solutions and machine learning products. Prior to joining INT, he oversaw development projects in both rural and tribal areas, assessing implementation progress
and identifying corruption schemes.
You are part of INT’s Data Lab team. How has the
digital landscape changed for INT in recent years?
In the past four years, the Data Lab has focused on
modernizing INT’s data ecosystem, replacing its legacy case management system, and developing next
generation tools. In particular, our dedicated cloud
infrastructure has enabled us to develop more efficient, tailored, and scalable in-house tools, as well
as to run complex Machine Learning and Artificial
Intelligence (ML/AI) algorithms. We also launched
six online applications containing 22 data modules
to support data analytics across all INT functions.
This includes search engines connected to other
Bank systems that provide data in real time, interactive risk maps to help identify hotspots, and various
dashboards with dynamic visualizations and filters
for producing customized reports.

How have the use of data analytics and digital tools by INT
supported its anticorruption impact?
INT has made significant investments in cutting-edge technologies
that are poised to make an impact on its work in the near future, in
particular in the area of ML/AI. For example, we have been piloting
the use text mining and pattern detection systems, and while there
are technological and procedural challenges to overcome before
these systems can scale and be fully automated, the pilots have
yielded promising results for both preventive work and proactive
investigations. We are already using these tools to demonstrate
efficiency gains through machine-generated integrity risk summaries of audit documents, as well as algorithm-driven detection
of collusive bid rigging schemes that produce comparable analyses to manual methods, but in a fraction of the time. These and
other ongoing pilots should serve to give INT’s investigators and
preventive support teams more space to focus on high-impact
efforts in their work.

THE INTEGRITY VICE PRESIDENCY

« 9

What We Do

targeted training for identifying, mitigating, and managing fraud and corruption risks in WBG operations.

Carrying out the WBG’s anticorruption agenda is an inter-institutional effort that engages multiple offices. INT’s mission

Delivering on its mission requires the collective efforts of all

is to support the WBG’s development efforts by working to

of INT’s core functions. INT’s teams are organized through a

detect, deter, and prevent fraud and corruption in WBG-fi-

structure that achieves impact through collaboration, knowl-

nanced operations and by WBG staff and corporate vendors.

edge sharing, and cross-support among INT’s staff (see

INT’s efforts help ensure that WBG resources are used only

Figure 2).

for their intended purposes.
•

DETECT—Through complaint handling, reviews, and

investigations, INT ascertains whether firms or individuals have engaged in one or more of the WBG’s five
sanctionable practices. This mandate also includes
investigating allegations involving WBG staff and corporate vendors, which are adjudicated via administrative
processes outside the sanctions system.
•

team, and its Prevention, Risk, & Knowledge Management
(PRKM) team all report to INT’s Director of Investigations,
Strategy, and Operations, who in turn reports to and supports INT’s Vice President. The PRKM team consolidates the
Preventive Services Unit, Forensic Audit and Digital Forensics Unit, the Complaints Development Unit, and the Data
Lab to better leverage the synergies and insights these func-

DETER—When firms or individuals are found to have

more likely than not engaged in sanctionable practices
within WBG operations, INT pursues sanctions via settlement or proceedings in the sanctions system. Sanctions
hold wrongdoers accountable for their misconduct and
help deter others from engaging in similar behavior.
In addition, through the Integrity Compliance Office, the
WBG engages with sanctioned firms and individuals to
support their efforts toward meeting the conditions for
their release from sanction. Through these engagements,
the WBG emphasizes rehabilitation through entities’
adoption and effective implementation of appropriate
integrity compliance measures and promotes higher
business integrity standards in the countries where it
operates.
•

INT’s External and Internal Investigation teams, its Litigation

tions can bear, both for the benefit of INT investigations and
for strengthening preventive support for WBG operations.
The Integrity Compliance Office reports directly to INT’s
Vice President, in order to carry out its outreach and evaluation work independent of INT’s investigations, litigation,
and preventive functions. Also reporting directly to the Vice
President are the INT front office staff, the administrative
Core Services team, INT’s Learning Coordinator, and internal
WBG business partners.
INT Strategy Update (FY22–FY26)
This year, INT launched a Strategy Update that outlines
the priority shifts to be undertaken by the unit over fiscal
years 2022–26. It recognizes the importance for INT to
continuously evolve and adapt itself to align with changing
institutional needs and growing expectations of the WBG,

PREVENT—INT turns the unique knowledge gained

as well as to meet the modern corruption challenges facing

from its complaints, investigations, diagnostics, and

WBG operations. It was the culmination of an extensive con-

analytical activities into practical preventive advice and

sultative process that engaged and incorporated insights

FIGURE 2: INT Management Structure

Vice President
Director of Investigations, Strategy and Operations
Prevention,
Risk &
Knowledge
Management

External
Investigations

AFE, ECA, EAP

AFW/MNA, LCR,
SAR, IFC/MIGA

Internal
Investigations

Front Office
Litigation

Integrity
Compliance
Office

Core Services,
Learning
Business
Partners

Notes: AFE = Africa Eastern and Southern Region; AFW = Africa Western and Central Region; EAP = East Asia and Pacific Region; ECA = Europe and
Central Asia Region; LCR = Latin America and the Caribbean Region; MNA = Middle East and North Africa Region; SAR = South Asia Region; IFC =
International Finance Corporation; MIGA = Multilateral Investment Guarantee Agency.

10 » SANCTIONS SYSTEM ANNUAL REPORT • FISCAL YEAR 2022

from INT staff, WBG operational teams, and WBG senior
leadership, and was endorsed by the institution’s Audit
Committee.

DETECT: INT’s Investigations
Detecting fraud and corruption is a cornerstone of INT’s
mandate. Investigations are the primary means used by

The Strategy Update is centered on INT’s existing anticor-

INT to fulfill this mandate and represent a majority of INT’s

ruption mandate and builds on the solid foundation that

annual work program. While INT is an independent unit, its

already exists while identifying opportunities for INT to

investigations are conducted within the broader operational

deliver even greater impact. As such, investigations remain

context of the WBG and in service of the institution’s mission

the central pillar of INT’s work program, and critical efforts

to end extreme poverty and promote shared prosperity.

across INT investigations, sanctions, prevention, and integrity compliance functions will continue. It identifies areas of
improvement, considering the evolving needs of the WBG
and best practices in the fight against corruption. In that
context, the Strategy Update is structured around three priority areas:

EXTERNAL INVESTIGATIONS

By detecting fraud and corruption in WBG operations, INT’s
external investigations help bring accountability for misconduct and create a more predictable, transparent, and fair
business environment. This improves competition among
the companies and consultants that implement WBG-fi-

• Enhancing INT’s risk-based approach to investi-

nanced projects, enhances the quality of goods and services

gations, to focus resources on cases that deliver the

provided to member countries, and maximizes the impact of

greatest impact for the WBG and/or help the institution

WBG financing.

identify and mitigate the most significant risks in its
operations. This shift will be accompanied by efforts to

Complaint Intake

bolster a more proactive and intelligence-driven model

The Complaints Development Unit (CDU) receives and

for INT investigations that supplements the current

responds to submissions and develops actionable com-

complaints-driven model.

plaints that fall under INT’s mandate. During FY22, closer

• Strengthening the delivery of timely and actionable
prevention support to WBG operations, with a more
structured approach designed to provide early identification and mitigation of fraud and corruption risks.
This work will continue to be largely demand driven and
responsive to the needs of operations.
• Developing INT’s knowledge management processes
and products to help feed lessons learned from INT’s
broad exposure to integrity issues into the project
design, program delivery, and broader management of
integrity risks in WBG-financed projects. This knowledge
will be drawn from across INT’s functions, including data
gathered during complaints screening, forensic findings,
and investigative and compliance casework to support
prevention.

collaboration between the CDU and INT’s Preventive Services Unit, Data Lab, Risk Analysis team, and Forensic
Services Unit enabled a more holistic assessment of complaints across relevant units in INT. This has also facilitated
interaction with operational counterparts in the follow-up to
a complaint, as well as in INT’s preventive support to Operations, where appropriate.
INT received 3,381 complaint submissions in FY22. Only a
small portion of these related to matters that are both within
INT’s jurisdiction as well as actionable (330) were assessed
by the CDU as a prelude to a potential external investigation.
A further 81 complaints were referred to INT’s internal investigations for their preliminary assessment and development
(please refer to the Internal Investigations section for more
details).

Underpinning the Strategy Update are key enablers that will

Investigations

empower INT to achieve greater impact in carrying out its

In FY22, INT opened 48 full investigations, each addressing

mission. These include: INT’s staff—its most critical asset;

one or more sanctionable practices. Despite the disruptions

increased utilization of technology and data; exploring pro-

caused by the COVID-19 pandemic, eight more new cases

gressive deployment of staff to strategic country locations;

were opened compared to FY21 (40), which constitutes a

strengthened partnerships both within and external to the

20% increase.

WBG; and robust internal operational processes. Overall,
the Strategy Update will endeavor to enhance the WBG’s
development impact through INT’s strengthened integrity
support.

Although constraints imposed by the global pandemic
became less stringent as FY22 progressed, travel restrictions continued to impact INT’s investigative process and

THE INTEGRITY VICE PRESIDENCY

« 11

FIGURE 3: Regional Breakdown of External Investigations Started in FY22

48 investigations
started in FY22

(22.9%)
AFE

(8.3%) (10.4%)
AFW
EAP

2 2

(33.3%)
ECA

(14.6%)
SAR

(4.2%) (4.2%)
LCR MNA

(2.1%)
IFC

FIGURE 4: Duration and Regional Breakdown of Active External Investigations at the end of FY22

94 investigations

(34%)

(17%)

(49%)

open for over
18 months

open for
12–18 months

open for less than
12 months

were still active at
the end of FY22

(22.3%)
AFE

(14.9%)
AFW

(12.8%)
EAP

5 4

(24.5%)
ECA

(13.8%)
SAR

(5.3%) (4.3%)
LCR MNA

(2.1%)
IFC

FIGURE 5: Duration and Regional Breakdown of Completed External Investigations in FY22

20 (64.5%) were substantiated
14

31 investigations
were completed
by end of FY22

(45.2%)

(35.5%)

(19.4%)

completed in over
18 months

completed between
12–18 months

completed within
12 months

(25.8%)
AFE

(6.5%) (12.9%)
AFW
EAP

(12.9%)
ECA

(6.5%)
MNA

(22.6%)
SAR

(9.7%)
IFC

(3.2%)
LCR

demanded sustained flexibility and creativity in adopting

how to allocate on-the-ground resources. At the end of FY22,

new investigative techniques and tools. The urgency with

INT had 94 active external investigations across all of the

which the WBG mobilized to meet the needs of its member

WBG regions, as well as involving IFC operations.

countries during the pandemic fueled INT’s adaptation and
led to an unprecedented application of technology to facilitate the investigative process. Many of the lessons learned
during this adaptation process will serve INT well in the
coming years, as the enhanced experience in conducting
remote interviews and audits will create new opportunities
to streamline investigations and re-think when, where, and

12 » SANCTIONS SYSTEM ANNUAL REPORT • FISCAL YEAR 2022

If INT concludes that an investigation has uncovered sufficient evidence of one or more sanctionable practices, the
relevant allegations are deemed substantiated. INT then
produces a Final Investigation Report (FIR) summarizing the
findings of the investigation for submission to the appropriate operational staff, and, ultimately, to the WBG President.

In FY22, INT completed 31 investigations, three more com-

INTERNAL INVESTIGATIONS

pared to FY21, 20 of which it deemed substantiated.

Ensuring the integrity of the WBG’s own staff is critical to

Although the nature and complexity of investigations can
vary widely, INT strives to ensure that all its investigations
are impactful. This impact can be seen throughout the lifecycle of a WBG project. For example, information obtained
through the investigative process is shared with WBG management and operational counterparts, who are then better
equipped to consider risks during project preparation and
mitigate risks during project implementation. Public sanctions arising from INT investigations not only remove
debarred actors who have engaged in fraud or corruption
from WBG-funded activities, but also provide a clear and
powerful deterrent to misconduct and help strengthen and
enforce accountability in public tenders in countries and
sectors receiving WBG financing.
Once an investigation has been substantiated, INT may
seek sanctions against the firm or individual involved in the
misconduct. Sanctions can be imposed either through a
sanctions proceeding or a negotiated settlement. In sanctions proceedings, INT prepares a Statement of Accusations
and Evidence that presents in detail the evidence of sanctionable conduct. The two-tier sanctions system decides
whether INT’s accusations against a respondent are sup-

maintaining the institution’s credibility in the global anticorruption arena. Through its internal investigations, INT
reviews allegations of fraud and corruption involving WBG
staff occurring in WBG operations or supported activities (i.e., operational fraud and corruption) or affecting the
WBG administrative budgets (i.e., corporate fraud and corruption). Examples of allegations against staff within INT’s
investigative mandate include abuse of position for personal
gain, misuse of WBG funds or trust funds, embezzlement,
fraud, corruption, collusion, coercion, and attendant conflicts of interest or lesser included acts of misconduct. INT
also investigates allegations against corporate vendors
involving the sanctionable practices in support of the WBG’s
corporate vendor eligibility determinations, leading to possible ineligibility and, in some cases, debarment from WBG
operational contracts as well. Other allegations related to
workplace grievances (e.g., harassment, retaliation, sexual harassment, and discrimination) and other violations
of Staff Rules and WBG policies (misuse or abuse of travel
funds, staff benefits and allowances, petty cash or WBG
physical property) do not fall within INT’s mandate and are
separately investigated by the Ethics and Business Conduct
Department (EBC) under Staff Rule 3.00.

ported by sufficient evidence to sanction that respondent

Upon receipt of a complaint, INT internal investigations follow

and, if so, what sanction should be imposed.

a similar three-stage process as its external investigations:

In certain cases, INT may conclude that a negotiated settlement is an appropriate way to address sanctionable
misconduct. Settlements include three parts: a sanction, a
set of integrity compliance conditions, and ongoing cooperation requirements. The specific terms of a settlement take
into account, among other factors, the nature and gravity
of the misconduct, and the degree of cooperation provided
by the respondent to INT during the investigation. All settlements must be cleared by the WBG General Counsel and then
reviewed by the Chief Suspension and Debarment Officer.
Sanctions that may be imposed through a negotiated set-

intake and evaluation; preliminary inquiry; and investigation. An internal investigation entails gathering, weighing,
and analyzing facts, assessing the credibility of the parties
to a case, and producing a comprehensive report that provides a complete and balanced account, including all known
material facts and circumstances, relevant evidence, analysis and evaluation of the evidence, and objective fact-based
conclusions. During the course of a preliminary inquiry or full
investigation, INT may establish sufficient evidence to show
the allegations are unfounded, thus clearing a staff member
or corporate vendor of any wrongdoing. This is an equally
important outcome for both the WBG and the staff member

tlement or sanctions proceedings include: debarment with

or corporate vendor.

conditional release; fixed-term debarment; conditional

During FY22, INT pursued 28 cases involving WBG staff

non-debarment; letter of reprimand; and restitution. The
WBG’s baseline sanction for firms and individuals is a debarment with conditional release for three years, though there
is flexibility to determine the length, sequencing, and terms
of a sanction to suit the specific facts and circumstances of
a case. (Further details on the sanctions case submissions,

and 19 cases involving corporate vendors. Forty percent of
INT’s internal investigations involved WBG operations, 23%
involved WBG corporate administrative matters, and 36%
were a combination of both. In addition, INT assessed 170
complaints related to WBG staff and corporate vendors.

settlements, and sanctions imposed in FY22 are provided
later in this Report.)

THE INTEGRITY VICE PRESIDENCY

« 13

FIGURE 6: Subjects of Internal Investigations in FY22

Staff

Vendor

FIGURE 7: Outcomes of INT’s Closed Internal Investigations in FY22

Substantiated

4
20

Unsubstantiated
Unfounded

Notes: Substantiated case: A determination that, based on the results of the investigation, the evidence supports a finding of misconduct. Unfounded
case: The results of a preliminary inquiry or investigation established sufficient evidence supporting a conclusion that misconduct, as alleged, did not occur.
Unsubstantiated case: The preliminary inquiry or investigation, due to a lack of evidence, did not establish a reasonable basis to warrant further investigation or a reasonable belief to substantiate that misconduct was committed. Some credible information may have been present, which if corroborated would
have established a reasonable belief, but as it stands does not rise above the suspicion level. In other words, there was insufficient evidence to warrant an
investigation or to prove or disprove that misconduct was committed, and the decision then falls in favor of the staff member or corporate vendor.

It is critically important that the WBG meets the highest stan-

the staff member’s WBG employment. A staff member has

dards and addresses all material risks when it comes to the

the right to appeal the HRDVP’s disciplinary decision to

integrity of its own staff, and the entities it directly does busi-

the WBG’s Administrative Tribunal, whose judgments are

ness with. As a result, INT undertakes preliminary inquiries

binding.

of all credible allegations against WBG staff and corporate
vendors and does not triage cases according to risk factors
and other strategic priorities as is done for external investigations. Because of this, proportionally more allegations in
internal investigations are unsubstantiated following preliminary inquiries.

In FY22, INT conducted five Staff Rule 8.01 investigations
and substantiated staff misconduct in one case. As a result,
the HRDVP decided that the staff member will be ineligible
for future WBG employment, restricted from access to all
WBG premises, and that a disciplinary letter will remain in
the staff member’s personnel record.

Investigations of WBG Staff
INT’s procedures for investigating allegations of staff misconduct are governed by the policies set forth in WBG
Staff Rule 8.01 and are further informed by the judgments
issued by the WBG’s Administrative Tribunal. These procedures are designed to protect and respect the rights of
all staff members, including those who are accused, those
who report allegations, and those who serve as witnesses
in a case.

Investigations of WBG Corporate Vendors
INT’s investigations of allegations against WBG corporate
vendors support the institution’s vendor eligibility reviews.5
The Director of Strategy, Performance and Administration (SPADR) makes determinations of non-responsibility
of corporate vendors to exclude them from eligibility to
receive contract awards from the WBG and/or bid on WBG
corporate solicitations. Implicated vendors are provided an
opportunity to respond to the allegations before the SPADR

If the investigation establishes sufficient evidence, INT pre-

makes a determination. Potential sanctions imposed range

pares a FIR, inclusive of all evidence, and provides it to the

from a letter of reprimand to ineligibility for a specified or

implicated staff member for comment. INT then finalizes

indefinite period. Determinations by the SPADR cannot be

the report, incorporating the staff member’s comments

appealed.

and any INT rebuttal to those comments, and submits the
report to the WBG’s Vice President for Human Resources
(HRDVP) for decision. If the HRDVP finds misconduct, discipline can range from an oral reprimand to termination of

In FY22, INT closed seven corporate vendor cases, three of
which were substantiated. The SPADR declared two corporate vendors ineligible for WBG contracts, one of them for a

14 » SANCTIONS SYSTEM ANNUAL REPORT • FISCAL YEAR 2022

Impactful Investigations in FY22
In FY22, INT’s investigators continued to face unique

locally-based affiliate were debarred by the Sanctions

challenges due to pandemic-related restrictions.

Board. This firm was selected as a design consultant

Despite this, they concluded impactful investigations

based on falsified Curriculum Vitae (CVs) submitted in

that will influence INT’s future efforts—from identi-

its bid. The Sanctions Board noted “most concerningly”

fying sector-wide integrity risks, in order to remedy

that the vice president of the engineering firm who

them; to developing new insights into hybrid cases in

signed off on the falsified CVs was promoted to become

places affected by fragility, conflict, and violence (FCV);

the firm’s Chief Executive Officer after he was investi-

and through validating its investigative practices and

gated by INT.

policies—as much as they ensure that those who
engage in sanctionable misconduct in WBG operations

INT’s investigation protected two flagship contracts

will be held to account.

worth more than US$20 million. It also revealed that

Uncovering a Widespread Collusive and Corrupt

ensure the technical quality and integrity of the tender

Scheme

processes, could pose a substantial integrity risk. This

In FY22, INT completed an investigation into allega-

actionable information can be used to address similar

tions of corruption, collusion, fraud, and obstruction

integrity risks in other projects, sectors, and countries.

how the design consultants, who were involved to

relating to two flagship contracts under two projects
in the transportation sector in an East Asian country.

Affirming INT Oversight in Private Sector Operations

Ten entities and five individuals from six countries were

In FY22, INT concluded three landmark settlements in

sanctioned as a result of the investigation.

two projects funded by IFC. These settlements were
important as they affirmed INT’s vital oversight role

INT’s investigation uncovered evidence of a widespread

pattern of collusive and corrupt practices by design

has a number of tools to combat fraud and corrup-

consultants and bidders. In particular, INT substanti-

tion in their operations, as additional protections for

ated that the design consultant that was hired by the

all WBG-financed operations it is also important that

government to prepare the tender documents colluded

those who engage in these sanctionable practices are

with companies that intended to participate in the ten-

held accountable.

the WBG’s private sector operations. While IFC

der process. Under the scheme, the design consultant
solicited a company to prepare the tender documents,

The investigation addressed allegations of misconduct

and then submitted them to the government as the

in two IFC projects financing two airports in an African

design consultant’s own work. In return, the company

country and another airport in an Eastern European

had the opportunity to tailor the technical specifica-

country. It required a total of eight forensic audits, numer-

tions and other requirements in its favor, which gave

ous interviews, and several missions. In the end, the

it a substantially unfair competitive advantage in the

investigation found sufficient evidence of fraud and col-

subsequent tender process. In exchange for the ability

lusion against two multinational companies and a local

to influence the tender process in this way, the solicited

company. INT was able to settle the accusations against

companies often had to pay bribes to both the design

all three companies for substantial sanctions, with a mix

consultant and government officials. In some cases,

of debarments and conditional non-debarments.

when there were multiple design consultants, each
consultant would collude with one company and race
to include that company’s proposed technical specifications in the tender documents.

The successful completion of the IFC Airports investigation was a major victory for integrity and accountability in the WBG. The case demonstrated INT’s ability to
enforce integrity standards across all parts of the WBG.

As part of the latest sanctions cases following this

The investigative team’s successful collaboration with

investigation, a Europe-based engineering firm and its

counterparts in IFC, and especially with IFC’s Business

continued
THE INTEGRITY VICE PRESIDENCY

« 15

Impactful Investigations, continued

Risk and Compliance team provided a reliable and

had undisclosed financial interests and a management

robust platform for the engagement.

role. However, the Advisor obstructed INT’s investigation, causing INT to further investigate “supplemental

Ensuring Internal Accountability to Strengthen

allegations” generally related to the Advisor’s failure to

Integrity in WBG-Financed Projects

cooperate fully and truthfully with the INT investigation,

INT’s multi-pronged approach to investigations—exter-

including providing false information and destroying

nal investigations of firms and individuals involved in

evidence on his WBG mobile phone. Ultimately, the

WBG-financed contracts, and internal investigations

HRDVP found misconduct and terminated the Advisor’s

of WBG staff or corporate vendors—allows for more

employment with a permanent bar to rehire, based on

focused and efficient outcomes. In certain instances,

the substantiated supplemental allegations only. The

these prongs intersect, creating hybrid cases which

Advisor appealed to the WBG’s Administrative Tribunal,

combine subjects of both internal and external investi-

which upheld the outcome in FY22.

gations. One example shows their sometimes-inextricable linkage and has led to both the termination of

Upholding Decision from an INT Investigation by the

WBG staff and the debarment of companies bidding on

WBG’s Administrative Tribunal

WBG-financed projects.

In FY22, the WBG’s Administrative Tribunal dismissed
all claims by a former senior IT officer whose employ-

INT conducted a multi-year investigative and sanctions

ment was terminated for misconduct following a

process related to an alleged scheme by an Advisor to

complex INT investigation that closed in FY21. As part

a WBG Executive Director and several consulting firms

of his responsibilities, the former senior IT officer had a

that received multiple WBG-financed contracts. The

procurement role in the WBG’s IT department staff aug-

investigation benefitted heavily from a multi-team

mentation program, for which he determined the skills

approach across INT and the WBG, including not only

needed to deliver on IT projects and filled these posi-

investigators, but also forensic accountants, digital

tions with staff, also referred to as resources, of vendor

forensic specialists, lawyers, and IT specialists. INT

IT companies. Among other findings, INT’s investigation

investigated the firms for collusion, corruption, fraud,

determined that the staff engaged in a ten-year long

and obstruction in connection with a company allegedly

scheme of collecting payments from IT subcontractors

related to the Advisor. The company allegedly colluded

through which the staff directed the hiring of resources

with project officials to steer contracts to firms that it

under the IT department’s staff augmentation program.

partnered with in various joint venture arrangements.
The investigation into twelve companies and individuals who participated in the Bank-financed projects is

The WBG’s Administrative Tribunal found no basis to
the staff’s claim that INT’s findings were unfounded,

still ongoing.

or that the HRDVP’s disciplinary sanctions were dis-

The staff case against the Advisor focused on two

the staff misconduct, the case also highlighted a key

sets of allegations. The “original allegations” generally

integrity risk of the IT department’s staff augmentation

related to the Advisor’s alleged personal enrichment

program using more than one layer of subcontractors,

through multiple WBG-financed consultancy contracts

often referred to as multi-layer subcontracting, a prac-

involving a company, in which the Advisor allegedly

tice prohibited by the WBG.

proportionate to the offense. In addition to addressing

16 » SANCTIONS SYSTEM ANNUAL REPORT • FISCAL YEAR 2022

period of three years, and the other for a period of five years.
One substantiated case is pending a non-responsibility
determination by the SPADR as of the end of FY22.
Disclosures Made by WBG Staff
During FY22, 30 WBG staff (i.e., regular staff, former staff,
extended- and short-term consultants, and temporaries)
made protected disclosures related to internal investigations by raising misconduct allegations to INT’s attention,
including staff qualifying for whistleblower protection
under Staff Rule 8.02.6 In addition, 87 preliminary external investigations that were opened in FY22 (26% of total)
were based on information provided to INT by WBG staff.
INT is grateful to those staff members who have forwarded
to INT concerns of suspected misconduct, including allegations that may threaten the operations or governance
of the WBG, and INT appreciates the assistance and cooperation provided by many staff members in the resulting
investigations.

DETER: Sanctions, Referrals, and Integrity
Compliance
INT’s sanctions cases, and the resulting decisions of OSD
and the Sanctions Board, are one way in which the WBG
gives effect to INT’s investigative findings. Debarments protect WBG resources by excluding firms and individuals that
have engaged in sanctionable misconduct from its projects.
Referrals to national authorities or other organizations,
when appropriate and deemed to be impactful, can also
help prompt actions that increase the effectiveness of INT’s
investigative work.
The WBG’s standard conditions for release from sanction,
which include the development and implementation of an
integrity compliance program, further enhance debarment’s
deterrent value. Sanctioned firms and individuals may only
pursue new WBG-supported work after they have taken
concrete steps, satisfactory to the WBG, to improve their
business practices.

Impactful Settlement: Resolving Misconduct with Requirements for Better
Business Practices
World Bank investments in large-scale infrastructure

Under the settlement, the subsidiaries were sanctioned

projects can help support inclusive and sustainable

with debarment for 15 and 34 months, respectively,

growth and promote private sector opportunities in

followed by six months conditional non-debarment

developing countries. To achieve these goals, it is vital

for each. The parent company was also sanctioned

for companies that bid on the contracts in these proj-

with conditional non-debarment for 21 months. The

ects to abide by the highest business practices and

settlement also required that the companies develop

standards. Yet, some companies still seek unfair advan-

an integrity compliance program that reflects the

tages through corrupt practices.

principles set out in the World Bank Group Integrity

In FY22, INT reached a settlement agreement with
a large, Europe-based manufacturer of hydropower
equipment and two of its international subsidiaries,

Compliance Guidelines and continue to fully cooperate
with INT. In addition, the companies committed to paying restitution in the amount of EUR 1.7 million.

following the subsidiaries’ acknowledgement of respon-

These conditions can have an outsized impact over the

sibility for engaging in collusive, fraudulent, and corrupt

long-term, as the internal changes that will be required

practices. Under the World Bank projects, both of the

by the companies have the potential to positively shape

subsidiaries arranged through a commercial agent

the business practices of a significant international pri-

to gain improper tender advantages—for instance,

vate sector actor. The restitution requirement will also

advance access to confidential information—from pub-

help ensure that there is a direct remedy by the compa-

lic officials, while one of the subsidiaries also made, on

nies to the countries whose projects were impacted by

three different occasions, improper payments to the

their improper practices.

commercial agent to obtain favorable decisions from
public officials during contract execution.

THE INTEGRITY VICE PRESIDENCY

« 17

SANCTIONS

INT made five referrals to three different recipients. (A list of

In FY22, INT submitted 18 sanctions cases, and 12 settle-

these referrals is provided in Annex D of this report.)

ments to OSD for review. An additional three settlements
were submitted to the EO for IFC for review. As a result of
these and earlier INT-submitted cases and settlements, the
WBG debarred, or otherwise sanctioned, 35 firms and individuals. (For more information on the decisions underlying
the sanctions cases, please see the OSD and Sanctions
Board sections of this report.)

INTEGRITY COMPLIANCE

The Integrity Compliance Office (ICO) had an active year of
engagements with sanctioned entities working to meet their
conditions for release from WBG sanction. In that regard,
the ICO notified 33 newly sanctioned entities of their conditions for release, and actively engaged with 81 sanctioned
entities during FY22.7 The ICO also notified 36 entities that

The WBG increases awareness of sanctions and bolsters
their deterrent impact by making its sanctions decision
transparent and public. Cross-debarment—under which
the African Development Bank (AfDB), Asian Development Bank (ADB), European Bank for Reconstruction
and Development (EBRD), Inter-American Development
Bank Group (IDB), and WBG recognize one-another’s
public debarments of more than one year’s duration—further increases that deterrent effect. Firms and individuals
know that engaging in sanctionable misconduct under a
WBG project carries consequences beyond just the WBG.
In FY22, the WBG recognized 72 cross-debarments from
other MDBs, and 30 WBG debarments were eligible for
recognition.

their sanctions would be continued beyond the initial period

Settlements provide a complementary way for the WBG
to resolve cases of sanctionable misconduct. Under WBG
settlements, settling parties acknowledge wrongdoing,
agree to a sanction, commit to develop and implement
an integrity compliance program, and agree to cooperate further with INT. This cooperation provides INT with
information that can be used to advance additional investigations and cases. For example, one of the Sanctions
Board decisions issued in FY22 involved misconduct
by three firms; two settled and cooperated with INT,
which aided INT’s sanctions case against the third firm.
Through their efficient resolution of cases and detailed
compliance and cooperation provisions, settlements provide a valuable tool to promote higher integrity standards
in WBG-supported projects.

the world, including in fragile and conflict-affected situations.

REFERRALS

Referrals are both a means for INT to cooperate with other
authorities, and a manifestation of the fiduciary duty that
underlies INT’s mandate and work. INT sends referral reports
to relevant WBG counterparts in member countries when
evidence indicates that a WBG member country’s laws may
have been violated and INT assesses that a referral could be
impactful. INT also shares information with counterparts in
other MDBs and other international institutions when that
information may be relevant to their operations. In FY22,

18 » SANCTIONS SYSTEM ANNUAL REPORT • FISCAL YEAR 2022

of sanction, until such time as they met the conditions
imposed for their release from sanction. At the end of FY22,
406 entities were under sanctions with conditional release,
59 of which were actively engaging with the ICO at that time.
The ICO also reviewed the integrity compliance materials of
several entities in connection with INT’s pre-sanction interactions with respondents and settlement discussions.
During FY22 the ICO determined that 22 entities had met
their conditions for release from sanction, and that one entity
had met the conditions for the conversion of its debarment
with conditional release to conditional non-debarment. The
released entities include large multinational companies, stateowned enterprises, and small companies operating around

During FY22, the ICO continued conducting virtual site visits
to speak with relevant personnel of sanctioned companies
and assess their implementation of integrity compliance
controls. The ICO also conducted its first in-person site visit
to a sanctioned entity since the COVID-19 pandemic and
looks forward to further resuming in-person engagements.
Notably, in FY22, the ICO began sending interim notices
to entities sanctioned with release conditions who are not
engaging with the ICO, approximately half-way through their
respective initial periods of WBG sanction, inviting them to
engage. The ICO took this step to further encourage such
entities to work with the ICO toward meeting their respective
conditions for release from WBG sanction. Interim notices
were sent to 62 sanctioned entities in FY22, leading to several new engagements. The interim notices are in addition
to the initial notices sent by the ICO to entities sanctioned
with release conditions following the imposition of their
sanctions. The ICO also continues to send to entities who
have not met the applicable conditions for release from WBG
sanction advance notice that their WBG sanction will be continued (or converted to a debarment with conditional release
in the case of a conditional non-debarment) until such time
as the conditions for release have been met, further inviting
them to engage with the ICO toward that end.

Impactful Integrity Compliance Reforms
Among the entities that met their conditions for release

and ICO, and many recommendations were adopted by

from sanction in FY22 were a number of companies

the company. It is also notable that the monitor’s work

within the corporate group of Novonor S.A. (formerly

was undertaken in the context of cooperation between

Odebrecht S.A.). Novonor’s subsidiary CNO S.A. (for-

the Bank, the Inter-American Development Bank, and

merly Construtora Norberto Odebrecht S.A.) and its

the U.S. Department of Justice, all of which were over-

controlled affiliates were debarred, with conditional

seeing aspects of the company’s compliance reforms

release, for a minimum period of three years pursu-

pursuant to their own agreements with the company

ant to the terms of a settlement agreement entered

during portions of the three-year WBG sanction period.

into in 2019 with the Bank. The sanction was imposed
in connection with misconduct relating to the Bankfinanced Río Bogotá Environmental Recuperation and
Flood Control Project in Colombia. The settlement
agreement provided that the sanction would end at
the conclusion of the three-year period if CNO and its
affiliates had met the imposed conditions for release
at that time, including with respect to the development
and implementation of an integrity compliance program
reflecting the principles set out in the WBG Integrity
Compliance Guidelines (Integrity Guidelines). In accordance with that provision and the applicable Bank
Sanctions Procedures, the WBG Integrity Compliance
Officer determined that CNO and its affiliates had met
the conditions for release, and the companies therefore
were released from the sanction imposed under the settlement agreement effective as of January 29, 2022.8
During CNO’s three-year period of sanction, the ICO
engaged regularly with senior officials and representatives of CNO and its parent company, OEC S.A., a
roughly 15,000-person conglomerate that took responsibility for enhancing and implementing its integrity
compliance program not only at CNO but also across
its international operations. The ICO learned about
OEC’s efforts, which were pursued in response to the
misconduct underlying the WBG sanction and other
misconduct related to the so-called Lava Jato or Car
Wash operation in Brazil. OEC’s work was facilitated by
consultations with the ICO and a third-party integrity
compliance monitor retained by OEC in accordance
with its agreement with the Bank. Notably, OEC was
receptive to recommendations for enhancement of its
integrity compliance program from both the monitor

At the end of the three-year period, OEC had implemented a comprehensive integrity compliance program
reflecting the principles set out in the Integrity Guidelines,9 and evidence of the company’s adherence to the
program in its daily operations had been provided to the
ICO. OEC also established a compliance function led by
its independent Chief Compliance Officer, who reports
directly to the Board of Directors’ Integrity and Audit
Committee and who counts on the support of a team
of full-time compliance professionals and local Integrity
Focal Points.
This case is another example of how the ICO’s collaboration with sanctioned entities can have a broad
developmental impact. Through OEC and the numerous other companies working with the ICO, the integrity
compliance principles endorsed by the WBG take practical effect and support the positive rehabilitation of not
only the sanctioned companies themselves, but also
their supply chains and business communities. Indeed,
OEC demonstrated during its period of sanction that
it emphasizes its integrity reforms as a selling point in
interactions with potential clients and business partners, expects its business partners to abide by integrity
principles, and serves as a leader in compliance-focused organizations. Notably, OEC also continues to
collaborate with the ICO as a mentor to entities outside
its corporate group that are currently sanctioned by
the WBG, providing guidance on their efforts to develop
effective integrity compliance reforms and meet their
own conditions for release from WBG sanction. The ICO
looks forward to further collaboration with OEC and its
affiliates to promote integrity compliance globally.

THE INTEGRITY VICE PRESIDENCY

« 19

Corporate Integrity Compliance Outreach

By engaging with sanctioned entities working to meet their

In FY22, the ICO continued promoting integrity compli-

conditions for release from sanction and collaborating

ance principles among businesses and other stakeholders.

with industry groups and transnational organizations, the

Beyond its core work with sanctioned entities, the ICO cham-

ICO promotes integrity compliance principles and reforms

pions the adoption of tailored integrity compliance programs

among companies of all sizes and in all sectors and geog-

and related controls as a good business practice for all

raphies. The ICO’s network of champions for integrity

companies. Indeed, the best use of an integrity compliance

compliance—including experienced compliance monitors

program is as a means of preventing misconduct, in addi-

and experts and released companies serving as mentors and

tion to enabling an entity to react appropriately if something

speakers at outreach events—further broadens the impact

does go wrong. To that end, ICO team members participated,

of the ICO’s work.

as presenters, in various virtual conferences and events
throughout FY22. Some highlights include:

PREVENT: Prevention, Risk & Knowledge

• A webinar titled “The Importance of Compliance Pro-

To support new directions under the INT Strategy Update,

grams in World Bank Projects,” hosted by the Brazilian

the teams responsible for complaint handling and develop-

Association of Infrastructure and Basic Industries.

ment (CDU); forensic audit and digital forensics (FSU); data

• A panel discussion focused on WBG sanctions and
integrity compliance programs, hosted by Ethisphere.

systems, tools, and innovation (the Data Lab); risk analytics;
and preventive services (PSU) have been brought together
under the Prevention, Risk, and Knowledge Management

• A panel discussion titled “Different Approaches to Moni-

(PRKM) unit. Closer collaboration between these teams

torship and Post-Resolution Compliance Requirements,”

enables a more risk-based approach to the assessment,

as part of the Women in Investigations Conference,

follow-up, and analysis of complaints; the prioritization of

sponsored by Global Investigations Review.

cases; and the proactive identification of high-risk projects

• An event titled “Improving the Effectiveness of Compliance Programs of Chinese Enterprises,” sponsored by
organizations including the Beijing New Century Academy on Transnational Corporations and the Siemens

and cases. It is also enabling INT to gather new kinds of preventive insights from complaints data, and to develop new
risk analytic methods and tools to inform our advice to World
Bank operations.

Integrity Initiative.

The Value of Integrity Compliance
Companies that work with the ICO continue to report that they appreciate the business value of implementing effective integrity compliance programs and plan to continue implementing them as an ongoing part of their business
operations, even after being released from WBG sanction. For example, here is the perspective of one company that
was recently released from WBG sanction on its efforts to develop and enhance its integrity compliance program
and related reforms (in the company’s own words and without endorsement on the part of the ICO):
“World-class corporate governance systems and integrity compliance programs require time and discipline to
mature. Well-designed codes, policies, processes, and accountability frameworks are crucial but need to be built
on efforts for nurturing ethics and compliance as guiding principles for individual conduct. Those are some of
the lessons we learned in the transformation journey our company has embraced in the last six years. The WBG
Integrity Compliance Guidelines have been a key reference for the development of OEC’s Integrity Program. Even
more important was the constructive dialogue with the Bank´s ICO and independent monitor, which helped to
implement a program that effectively addresses risks and strengthens the company´s business.”
Alexandre Baltar
OEC Chief Compliance Officer

20 » SANCTIONS SYSTEM ANNUAL REPORT • FISCAL YEAR 2022

New business processes and tools have been devel-

of themes, issues, and trends are also being developed. This

oped this year to support these goals, bringing in diverse

will help generate new insights to inform INT’s investigative

expertise from across INT in assessing and following up

priorities, preventive advice to Operations, and the focus and

on complaints, or supporting collaboration between data

content of knowledge products.

scientists and investigators in developing new data-driven
investigative methods. INT will continue to enhance these

Corporate Integrity Disclosures and Preventive Advisory

processes and tools with a view to honing its risk analy-

Work

sis frameworks and generating advisory and knowledge

The PSU monitors the World Bank’s portfolio of proposed

products that help operational teams better respond to

and active projects for potential integrity risks associated

the evolving integrity risks faced by the WBG, and address

with INT cases and complaints, raises integrity concern

and mitigate these earlier in project cycles before issues

flags where appropriate, and recommends mitigation mea-

arise. PRKM teams are also collaborating ever more closely

sures to project teams. The PSU also provides on-demand

with key counterparts in the WBG, notably with the Opera-

support to task teams in the preparation and implemen-

tions and Country Services (OPCS) unit in developing data

tation of high-risk projects, drawing on its experience

driven approaches to identifying and addressing integ-

identifying and mitigating integrity risks in different sectors,

rity risks, and to developing approaches that continue to

types of operations, and operational contexts. The PSU

support the WBG’s evolving response to the COVID-19 pan-

has continued to meet the challenge of delivering on this

demic and other emerging crises. The following highlights

mandate in the context of the Bank’s increased financing

occurred in FY22.

in response to the pandemic, as well as the Bank’s evolving
response to other crises and emergency situations around

Complaint Review, Analysis, and Development

the world. In addition, the PSU has assisted in identifying

This year has seen the launch of new complaint-handling

and mitigating integrity risks in the preparation phase of a

workflows and data tools to support a more risk-based

number of selected programs or projects that operational

approach to the analysis, follow-up, and assessment of

teams considered particularly high-risk due to a combina-

complaints. Although the core function of the CDU remains

tion of factors relating to challenges in the sector, the type

the same—receiving and responding to submissions and

of operation and/or the operating context. Other signifi-

developing actionable complaints that fall under INT’s man-

cant engagements have included the delivery of training

date—closer collaboration between the CDU and the PSU,

to PIUs, in collaboration with fiduciary staff in the Regions

FSU, Data Lab, and Risk Analysis team has enabled a more

(more information is provided below). The PSU is now also

holistic assessment of complaints with the participation of all

working more closely with the CDU to provide contextual

relevant units in INT. New business processes were created

insight to the assessment of complaints, and to assist in

this year to bring in expertise from across INT in reviewing

timely follow-up with task teams to aid them in addressing

and assessing complaints, and to streamline decision mak-

issues raised. The PSU is also engaging in more sustained

ing around complaints. New data management frameworks

communication and preventive support to Bank operations

and tools to enable a more systematic analysis and tracking

in the context of ongoing investigations.

Company Risk Screening for Preventive Impact
To make operational colleagues aware of relevant investigations involving suppliers who may be participating
in Bank-financed projects, INT provides screening of supplier names via the Bank’s procurement system. This
screening system allows INT to provide timely, risk-relevant information to task teams at specific procurement
steps. This year has seen many successful engagements as a result of this screening approach, with INT providing
advice to operational teams that resulted in more in-depth reviews of bids as well as the discovery of fraudulent
documents. This approach both mitigates risk in World Bank-financed tenders, and provides additional investigative material for INT.

THE INTEGRITY VICE PRESIDENCY

« 21

Data and Risk Analytics

• WBG corporate onboarding programs. Through the

INT is expanding its risk analytics work program to lever-

WBG’s new staff orientation, as well as specialized

age new capacities made possible by its recently developed

sessions for incoming Executive Directors and Board

cloud infrastructure. The focus in FY22 has been on piloting

Officials, recruits to the WBG’s Young Professional Pro-

new data analytic applications and supporting more sys-

gram, and staff working in FCS contexts, these trainings

tematic analysis of existing INT databases, with an initial

highlight the Bank’s stance against fraud and corrup-

focus on the analysis of complaints data. Pilot data science

tion, the work INT does, and staff’s duty to report fraud

projects have explored the use of artificial intelligence to

and corruption and channels for doing so.

automate the screening of documents generated by project
audits, the tailoring of software to enable the detection of

• Trainings to raise integrity risk awareness. Organized
in collaboration with key Bank units, including country

collusive patterns in procurement data, and the exploration

office staff and Financial Management teams, these

of the uses of satellite and remote imaging for investigative

trainings raise awareness of INT’s work, the WBG’s

and preventive purposes. These projects are at the proof-of-

sanction system, and how staff with oversight of Bank-fi-

concept stage but have already yielded initial results in the

nanced projects, as well as government and private

identification of operational risks, in developing complaints,

sector officials, can better understand integrity risks and

and in the proactive identification of investigative leads. INT

report concerns to INT. This year, these trainings were

has also continued to offer on demand company risk pro-

held for Bank staff and project implementation teams in

filing to Operations to assist with integrity due diligence,

countries including Azerbaijan, Haiti, India, Kenya, Mon-

leveraging INT data.

golia, Papua New Guinea, Paraguay, Solomon Islands,
Tajikistan, and Zambia.

Forensic Audits and Digital Forensic Services
The FSU and the Digital Forensics Lab have been integrated

• Trainings to operational staff. These targeted programs

this year into a single larger team. Both functions play a

focus on operational issues, financial management

critical role in INT investigations, but also have an important

concerns, and how the Bank can improve its anticorrup-

role to play in other work programs, including risk analysis,

tion efforts through its Good Governance Framework,

complaint assessment and prevention. The integration of

Corruption Risk Assessments, and collaboration with

these functions supports the growing demand for digital

anticorruption agencies.

forensic services in investigations as well as closer collaboration with other teams in PRKM. The FSU has continued

• Collaborations with other WBG units. INT delivered
joint trainings with the EBC, including a notable training

to deliver (mostly virtual) capacity building and training in

on understanding staff’s role and rights in investigations,

forensic audit skills in collaboration with teams from across

in which EBC and INT investigators discussed common

the Bank.

experiences and questions from staff, as well as resources
available for raising misconduct-related concerns.

Training and Outreach
Through targeted trainings to World Bank staff, clients, and
business partners on its work, INT helps to strengthen understanding of the key risks posed by fraud and corruption to
the Bank’s work. INT’s engagements also raise awareness
of the guidance and resources that INT can provide to help
WBG staff and clients identify, mitigate, and manage these
risks in their work.

Engaging with Anticorruption Partners
In FY22, INT’s participation in key multilateral forums affirmed
its and the WBG’s commitment to advancing the global anticorruption agenda. Notably, INT’s Vice President and Director
headed a WBG delegation to the Ninth session of the Conference of the States Parties to the United Nations Convention
against Corruption, which brings together practitioners and

In FY22, INT delivered and participated in a wide range of

experts to support improvements for international coop-

awareness raising sessions, trainings, and outreach efforts,

eration in tackling corruption. The delegation also included

along with maintaining an eLearning course “Integrity Is Your

representatives from the WBG’s Governance Global Practice

Business”, reaching about 2,800 WBG staff, project imple-

and the Stolen Asset Recovery (StAR) Initiative. The WBG

mentation units, government counterparts and officials, and

representatives reiterated the strong stance that the WBG

private sector representatives. These included INT’s partici-

takes against corruption and highlighted the technical assis-

pation in:

tance and support the institution provides member countries
to strengthen their anticorruption and governance systems

22 » SANCTIONS SYSTEM ANNUAL REPORT • FISCAL YEAR 2022

and support stolen asset recovery. In addition to their partic-

In addition, INT engaged with its partners through attendance

ipation on multiple expert panels, INT’s Vice President and

at the Organisation for Economic Co-operation and Develop-

Director held bilateral meetings with representatives from

ment’s (OECD) Working Group on Bribery in International

government integrity and anticorruption offices.

Business Transactions meetings, the United Nations Office

In May, INT’s Vice President met with a delegation from
the Republic of Korea, led by the Minister of Justice, to discuss opportunities to strengthen cooperation between the
country and the World Bank on anti-corruption and other
integrity matters. INT has a strong partnership with the government of Korea, which has been supporting collaborative
initiatives including the secondment of experienced Korean
prosecutors to INT, the development of an IntegrityCompliance Guidebook for small and medium enterprises, and the
provision of a grant to build a training platform to promote
corporate integrity compliance.

on Drug and Crime’s (UNODC) Global Operational Network
of Anti-Corruption Law Enforcement Authorities (GlobE Network) launch and plenary meetings, and the Conference of
International Investigators, among other meetings. In total,
INT staff participated in more than 40 programs, workshops,
and panels to raise awareness of integrity risks to external
audiences, promote integrity compliance standards in the
private sector, and strengthen ties with peer anticorruption
organizations. INT also continued its standing collaboration
with the other MDBs through the Heads of Integrity meetings. This roundtable allows the MDB integrity offices to
discuss topics of common interest, discuss challenges
arising from anticorruption investigations, and advance the
MDB’s collective efforts to strengthen and harmonize the
work of their offices.

THE INTEGRITY VICE PRESIDENCY

« 23

This year is particularly momentous for OSD as
our unit celebrates 15 years of work dedicated to
promoting good governance by addressing fraud and
corruption impacting World Bank operations.

24 » SANCTIONS SYSTEM ANNUAL REPORT • FISCAL YEAR 2022

The Office of Suspension and Debarment
The first tier of the World Bank’s adjudicative sanctions system

Introduction by
Jamieson A. Smith,
Chief Suspension and
Debarment Officer

We also continued our outreach and knowledge-sharing
activities to inform internal and external stakeholders about
the mission, processes, and results of the WBG’s sanctions
system. One relevant event was a hybrid-format international

I am thrilled to share the WBG
Sanctions

System Annual

Re-

port for FY22 with our internal and
external stakeholders. The Office
of Suspension and Debarment (OSD) plays a pivotal role
in ensuring that the World Bank’s development financing is
used solely for its intended purposes. This year is particularly
momentous for OSD as our unit celebrates 15 years of work
dedicated to promoting good governance by addressing
fraud and corruption impacting World Bank operations.
Over the past fiscal year, OSD continued to successfully deliver
on its core mandate of providing the first level of adjudication
in sanctions cases. Adding to OSD’s efficiency in providing an
impartial and timely sanctions process, the sanctions system
deployed a new digital case management system designed to
streamline our case flow and facilitate interactions between
OSD, INT, and the Sanctions Board. Throughout its 15 years
of operations, OSD has identified best practices and learned
valuable lessons from our casework. This experience positions OSD to continuously contribute to the development of
WBG sanctions policy. During the past year, OSD engaged in
discussions with numerous internal stakeholders to ensure
that the lessons learned from practice are integrated into the
sanctions system’s framework.

symposium on Supranational Responses to Corruption
organized by OSD in collaboration with leading institutions,
such as the American Society of International Law and the
Anti-Corruption Division of the OECD. The purpose of the
symposium was to study and reflect upon existing and
prospective anticorruption efforts that transcend national
boundaries or governments. Further, OSD is particularly
proud to have published the Global Suspension & Debarment
Directory in partnership with the International Bar Association’s Anti-Corruption Committee. The Directory provides consultative information on the exclusion systems of
23 different jurisdictions and institutions and serves as a
unique one-stop resource on the topic for practitioners and
academics.
As a key player in the sanctions system, OSD’s work has a
global footprint in the fight against corruption. We at OSD
will persevere in our efforts to maintain the sanctions system’s integrity and objectivity and contribute to the larger
anticorruption community by sharing the knowledge and
experience gained over a decade and a half of work. I am
pleased to present this summary of OSD’s operations and
achievements over the past fiscal year.
Jamieson A. Smith
Chief Suspension and Debarment Officer

THE OFFICE OF SUSPENSION AND DEBARMENT

« 25

Who We Are
The Office of Suspension and Debarment (OSD) is the first

to evaluate each sanctions case solely on its merits and in

tier of the World Bank’s two-tiered adjudicative system and

accordance with the Bank Procedure: Sanctions Proceedings

functions similar to an administrative judicial office of first

and Settlements in Bank Financed Projects (Sanctions Pro-

instance. It is tasked with impartially reviewing accusations

cedures). In deciding a case, the SDO is entirely independent

brought by INT against respondent firms and individuals

and does not take instructions or recommendations from

and determining whether there is sufficient evidence that

any other person or unit.

a respondent has engaged in sanctionable misconduct. If
there is sufficient evidence of misconduct, OSD commences
sanctions proceedings against the respondent and recom-

The SDO is supported by three staff attorneys, one legal consultant, one paralegal, one program assistant, and up to two

mends an appropriate sanction.

law student interns. During FY22, OSD’s staff members and

OSD is an independent unit within the World Bank and is

Brazil, China, Greece, Kazakhstan, the Netherlands, Romania,

headed by the Chief Suspension and Debarment Officer

Tajikistan, the United States, Denmark, and Vietnam—and

(SDO), who is appointed by and reports to the Managing

brought solid expertise in international development, anticor-

Director and WBG Chief Administrative Officer on matters

ruption, corporate law, public procurement, and compliance.

related to budget and management. The SDO is required

All of OSD’s staff are normally based in Washington, DC.

consultants had diverse regional backgrounds—hailing from

Pictured: World Bank Office of Suspension and Debarment (left to right): Riya Gavaskar, Program Assistant; Muslima Maksudzoda,
Legal Consultant; Gaukhar Larson, Counsel; Jamieson Smith, Chief Suspension & Debarment Officer; Hai Anh Tran, Legal Intern;
Collin Swan, Senior Counsel; Kaiqi Bao, Legal Intern. (Not pictured: Alexandra Manea, Counsel, Haiyue “Stephanie” Xue, Paralegal)

OSD Staff & Consultants At-A-Glance

STAFF &
CONSULTANTS

FROM

COUNTRIES

26 » SANCTIONS SYSTEM ANNUAL REPORT • FISCAL YEAR 2022

SPEAKING

LANGUAGES

69%
FEMALE

31%
MALE

Muslima Maksudzoda, Legal Consultant
Muslima Maksudzoda is a Legal Consultant at OSD, where she assists the SDO and staff
attorneys with the review and disposition of sanctions cases and other office activities. Ms.
Maksudzoda holds a law degree from the Russian Tajik Slavonic University in Tajikistan and a
master’s degree in International Legal Studies from American University’s Washington College
of Law. Prior to joining the WBG, Ms. Maksudzoda worked as an associate at AAA Law Offices
LLC, practicing business law in Tajikistan. Ms. Maksudzoda is also an alumna of the Fulbright
Foreign Student Program and a co-founder of a Tajik free online legal guide in support of the rule
of law and the fight against corruption.
What drew you to come work for OSD?
Working at OSD provides an opportunity to support the noble purpose of tackling corruption and
promoting integrity as an essential component of
development. The fact that I can contribute to this
greater cause and see positive results motivates me
and brings me satisfaction in the workplace. I share
the values and vision of OSD—a world free of corruption and a commitment to diversity and equality. As
a lawyer, I am attracted by the impartiality and independence in OSD’s work, which has the ultimate goal
of serving people’s well-being. OSD has a uniquely
engaging and supportive workplace culture where I
work side by side with, and learn from, outstanding
and accomplished specialists committed to high ethical standards.

What do you see as OSD’s impact on anticorruption efforts
in development?
OSD’s contribution to anticorruption efforts in international
development is manifold. The significant work that OSD does by
adjudicating sanctions cases involving development funds contributes to addressing corruption on a practical level. By imposing
sanctions on respondent firms and individuals, OSD not only safeguards development financing but also discourages the global
business community from engaging in sanctionable practices,
which promotes good governance and integrity. Further, OSD is
always open to opportunities for awareness-raising and other
knowledge activities to share the latest developments and lessons
learned from the WBG sanctions system’s anti-corruption efforts.
OSD organizes events, such as colloquia and symposia, that create
a platform for promoting cooperation and coordinated collective
actions in the global anticorruption space.

What We Do
The specific functions of the SDO include:
• Evaluating the sufficiency of the evidence presented
by INT in each case in a comprehensive, fully-reasoned
determination that analyzes factual, procedural, and legal
matters in detail.
• Determining if the evidence supports a finding that
the alleged sanctionable misconduct more likely than
not occurred, and if so, recommending an appropriate
sanction against the respondent. This sanctioning recommendation is based on the public WBG Sanctioning
Guidelines.
• Issuing a Notice of Sanctions Proceedings to each
respondent, which includes the allegations and corresponding evidence, as well as the SDO’s recommended
sanction.
• Temporarily suspending respondents from eligibility to
be awarded WBG-financed contracts pending the final
outcome of the sanctions proceedings.

• Reviewing any written Explanation submitted by a
respondent in response to a Notice of Sanctions Proceedings and deciding if the Explanation warrants a revision or
withdrawal of the recommended sanction.
• Imposing the SDO’s recommended sanction on each
respondent that does not appeal to the WBG Sanctions
Board and publishing a Notice of Uncontested Sanctions
Proceedings on the WBG’s sanctions website.
• Considering requests from INT for the early temporary
suspension of respondents that are subject to ongoing
investigations. The SDO will impose an early temporary
suspension if there is sufficient evidence to support at
least one accusation of sanctionable misconduct that,
if presented in a regular sanctions case, would have
resulted in a debarment of two or more years.
• Reviewing settlement agreements entered into between
the World Bank, through INT, and respondents to ensure
that they were entered into voluntarily and that their
terms do not manifestly violate the WBG Sanctioning
Guidelines.

THE OFFICE OF SUSPENSION AND DEBARMENT

« 27

• Handling incoming and outgoing cross-debarment notifications issued pursuant to the Agreement for Mutual
Enforcement of Debarment Decisions.
• Contributing to the continuous development of the
WBG’s overall sanctions policy.

OSD Case Summary
In FY22, OSD received 18 sanctions cases, reviewed 15
cases (including several cases submitted in the previous
fiscal year), and issued a fully-reasoned determination with
respect to whether INT presented sufficient evidence for

• Organizing outreach and knowledge-sharing activities

each sanctionable practice accusation in each case. OSD

to inform internal and external stakeholders about the

also reviewed 12 settlements that the World Bank, through

mission, processes, and results of the WBG’s sanctions

INT, entered into with respondents. Any given case may take

system.

a shorter or longer period of time to review depending on the
number of pending cases, the amount of evidence provided,
the number of respondents involved, the complexity of the
accusations made by INT, and any procedural issues.

OSD Legal Internship Program
Every year, OSD offers highly-motivated law students
an opportunity to be exposed to the mission and work
of OSD and the World Bank through a legal internship. The candidates are selected on a competitive
basis, ensuring diversity of backgrounds and nationalities. The objective of the program is to introduce
interns to practical aspects of the efforts against corruption via experience in the day-to-day operations
of the sanctions system, while working closely with
OSD and other WBG staff. OSD’s legal interns have
contributed new perspectives, ideas, and knowledge
to OSD and are able to improve their legal skills while
working in a multicultural environment.

The SDO referred eight of the 15 reviewed cases back to INT
for revisions after determining that there was insufficient
evidence to support one or more of the accusations made.
Once INT has made any necessary revisions to a case, the
SDO issues a Notice of Sanctions Proceedings to the named
respondents. In FY22, the SDO issued Notices of Sanctions
Proceedings in 14 cases, which resulted in the temporary
suspension of 20 respondents (14 firms and six individuals).
Under the Sanctions Procedures, respondents may submit
a written Explanation to the SDO within 30 days—and may
appeal to the WBG Sanctions Board within 90 days—after
receiving the Notice of Sanctions Proceedings. In FY22, OSD
reviewed a written Explanation submitted by one respondent and reduced the recommended sanction against this
respondent. Furthermore, 11 out of the 20 respondents
whose appeal deadline fell in FY22 did not appeal to the

In FY22, OSD
received 18 cases and
reviewed 15 cases.

In FY22, OSD
temporarily suspended

14 firms and
6 individuals.

In FY22, 11 out of 20 firms

Percentage of

and individuals did not

cases resolved at OSD’s

appeal and were sanctioned

level since OSD’s

via an uncontested

formation in 2007:

determination of the SDO.

67%

28 » SANCTIONS SYSTEM ANNUAL REPORT • FISCAL YEAR 2022

Submission of Respondent’s Explanation to the SDO
Within 30 calendar days after delivery of a Notice of Sanctions Proceedings to a respondent, the respondent may
provide a written Explanation as to why the SDO should withdraw this Notice of Sanctions Proceedings or revise the
recommended sanction. The SDO will consider reasonable requests for extensions of the Explanation submission
deadline on a case-by-case basis.
The respondent’s Explanation must be a single document in English not exceeding 20 pages, unless the SDO
approves a longer submission. The Explanation should present arguments by the respondent and attach any credible evidence in support thereof, including with respect to any relevant mitigating factors such as the respondent’s
minor role in misconduct, voluntary corrective action taken, or cooperation with the investigation.
Within 30 calendar days after receipt of an Explanation, the SDO will consider the arguments and evidence presented therein and may (i) withdraw the Notice of Sanctions Proceedings upon concluding that there is manifest
error or other clear basis for supporting a finding of insufficiency of evidence against the respondent or (ii) revise
the recommended sanction in light of evidence or arguments with respect to mitigating factors presented by the
respondent.

FIGURE 8: Percentage of cases & settlements reviewed by OSD by type of sanctionable practice*

150%
8%
6%

120%
25%

2%
4%

19%

13%

90%

11%

24%

20%

19%

21%
30%

12%

60%

81%

77%

FY18

FY19

86%

87%
70%

30%

0%
Fraud

Corruption

FY20
Collusion

FY21
Obstruction

FY22
Coercion

* Includes all INT submissions reviewed by OSD (sanctions cases and settlements) (221 in total). An individual case may include
several types of sanctionable practices, each of which is counted separately in the number of cases involving a certain type of
sanctionable practice. “Collusion” includes cases containing allegations of collusive misconduct governed bu the pre-2004
definition of fraudulent practice

THE OFFICE OF SUSPENSION AND DEBARMENT

« 29

WBG Sanctions Board, and the WBG imposed the SDO’s rec-

present in 30% and 11% of cases and settlements reviewed

ommended sanction against those respondents. Since OSD

this fiscal year, respectively.

began reviewing and issuing sanctions cases in 2007, about
67% of all cases did not involve an appeal and were resolved

Regional Breakdown of Respondents Sanctioned

at OSD’s level.

The World Bank, as one of the largest sources of funding and

Consistent with historical trends, most of the cases and settlements reviewed by OSD this fiscal year (70%) contained
at least one fraudulent practice accusation. Four of the 15

knowledge for developing countries, operates in countries
around the globe, and OSD receives sanctions cases and settlements against respondents from every region of the world.

cases and two of the 12 settlements reviewed this fiscal

As shown in the graphs above, this breakdown is relatively

year contained accusations of two or more different types

consistent in both the 110 cases that resulted in sanctions

of misconduct (e.g., fraudulent and corrupt practices). This

pursuant to the WBG’s adjudicative process (either by an

fiscal year, about 19% of cases and settlements reviewed

uncontested determination of the SDO or through a decision

by OSD alleged at least one collusive practice accusation.

of the WBG Sanctions Board), and the 103 cases resolved

Corrupt practice and obstructive practice accusations were

through settlement agreements with the World Bank, as

FIGURE 9: Regional Origin of Respondents

FIGURE 10: Regional Origin of Respondents

Sanctioned by the SDO and the WBG Sanctions
Board (110 Cases) (FY18–FY22)

Sanctioned by Settlement (103 Cases)
(FY18–FY22)

East Asia & Pacific
Europe & Central Asia

20%

Europe & Central Asia
34%

14%
Latin America & Caribbean

34%

Latin America & Caribbean
Middle East & North Africa

Middle East & North Africa
4%
North America
4%

14%

2%
2%

East Asia & Pacific

11%

South Asia

20%

North America

11%

Sub-Saharan Africa

South Asia

22%

Sub-Saharan Africa

FIGURE 11: Location of Misconduct Sanctioned

FIGURE 12: Location of Misconduct Sanctioned

by the SDO and the WBG Sanctions Board

via Settlement (126 Sanctions) (FY18–FY22)

(161 Sanctions) (FY18–FY22)

25%

26%

29%

34%

4%
14%
9%

14%

24%

17%

1%
East Asia & Pacific

Middle East & North Africa

South Asia

Europe & Central Asia

North America

Sub-Saharan Africa

Latin America & Caribbean

30 » SANCTIONS SYSTEM ANNUAL REPORT • FISCAL YEAR 2022

negotiated by INT and reviewed by the SDO. OSD’s tracking

the SDO takes into account any relevant aggravating and

of settlements reviewed by the SDO shows that respondents

mitigating factors as set forth in the Sanctions Procedures

who settled came from all over the world and were not lim-

and the WBG Sanctioning Guidelines. Promulgated in Sep-

ited to specific regions.

tember 2010, the WBG Sanctioning Guidelines provide

Of course, the regional breakdown of sanctions cases and
settlements does not necessarily indicate how prevalent
misconduct may be in any given region. INT receives complaints from all regions and considers many factors when
deciding how to best allocate its resources to investigate
potential misconduct. For its part, OSD plays no role in

non-prescriptive guidance on considerations relevant to
any sanctioning decision. The WBG Sanctioning Guidelines
contain a set of aggravating and mitigating factors and provide guidance as to when each factor would be applicable
and the suggested impact that each factor should have on
the sanctioning calculation.

INT’s review of complaints and selection of cases. Never-

OSD has tracked the SDO’s application of these aggravating

theless, the data suggests that WBG sanctions have a truly

and mitigating factors since the WBG Sanctioning Guidelines

global reach.

were promulgated in 2010. OSD uses this data to ensure that
the SDO is consistently evaluating and applying these fac-

Recommending an Appropriate Sanction—the WBG

tors across all respondents. The graphs below show how

Sanctioning Guidelines

often the SDO has applied a given factor across the 472

After reviewing a case, if the SDO finds sufficient evidence

respondents against whom the SDO has issued a sanctions

of misconduct against the respondent, the SDO will rec-

case since the WBG Sanctioning Guidelines came into effect

ommend an appropriate sanction. The SDO’s choice of

(excluding cases that (i) were ongoing as of June 30, 2022;

recommended sanction is guided by the relevant provi-

or (ii) were withdrawn or settled after an SDO recommen-

sions of the Sanctions Procedures, which provide for five

dation). Of those 472 respondents, 339 did not appeal to

possible sanctions: debarment with conditional release

the WBG Sanctions Board and were thus sanctioned via an

(the “baseline” or default sanction); debarment for a fixed

uncontested determination of the SDO. As shown below, cer-

period (without conditional release); conditional non-de-

tain factors have been applied more frequently than others,

barment; public letter of reprimand; and restitution. In

although the SDO considers the unique factual circum-

deciding on the appropriate type and length of sanction,

stances of each case.

Aggravating Factors from the WBG Sanctioning Guidelines

Mitigating Factors from the WBG Sanctioning Guidelines

AGGRAVATING
FACTORS INCREASE

1–5 years for this
category

AGGRAVATING FACTOR

MITIGATING FACTORS
DECREASE

MITIGATING FACTOR

A. Severity of the Misconduct

Up to 25%

A. Minor Role in Misconduct

1. Repeated pattern of conduct.
2. Sophisticated means.
3. Central role in misconduct.
4. Management’s role in
misconduct.
5. Involvement of public official or
World Bank staff.

Up to 50%; a greater
reduction may be
warranted in exceptional
circumstances.

B. V
oluntary Corrective Action
Taken

Up to 33%, however,
in extraordinary
circumstances, a greater
reduction may be
warranted.

C. Cooperation with
Investigation:

1–5 years for this
category

B. Harm Caused by the Misconduct

1–3 years for this
category

C. Interference with Investigation

10 years

D. Past History of Adjudicated
Misconduct

1. Harm to public safety/welfare.
2. Degree of harm to project.
1. Interference with investigative
process.
2. Intimidation/payment of a witness.

1. Cessation of misconduct.
2. Internal action against
responsible individual.
3. Effective compliance program.
4. Restitution or financial
remedy.

1. Assistance and/or ongoing
cooperation.
2. Internal investigation.
3. Admission/acceptance of
guilt/ responsibility.
4. Voluntary restraint.

Prior debarment or other penalty.

THE OFFICE OF SUSPENSION AND DEBARMENT

« 31

FIGURE 13: SDO Application of Aggravating Factors (472 Respondents) (12/16/10–6/30/22)

200
180

178

174

160
140
120
100
80
60
40

Repeated
pattern of
conduct

Sophisticated
Means

Central Management’s Involvement
Role in
Role in
of Public
Misconduct Misconduct
Official/
WB Staff

Harm to
Public
Safety/
Welfare

Degree of
Harm to
Project

Interference Intimidation/
Prior
with
Payment of Debarment/
Investigation
Witness
Other Penalty

FIGURE 14: SDO Application of Mitigating Factors from WBG Sanctioning Guidelines (472 Respondents)
(12/6/10–6/30/22)

250
219

200

150

137

100

38
24

37
21

0
Minor
Role

Cessation of
Misconduct

Internal
Action

Effective
Compliance
Program

Restitution Assistance/
Internal
Admission/
or
Ongoing Investigation Acceptance
Financial Cooperation
of Guilt
Remedy

Voluntary
Restraint

Passage
of Time

Previous
ETS (Years)

*Excludes (i) the 11 respondents against whom sanctions proceedings were ongoing as of June 30, 2022; and (ii) the 24 respondents whose cases
were withdrawn or settled after an SDO recommendation.
**“Passage of Time” and “Previous Early Temporary Suspension” are not listed in the WBG Sanctioning Guidelines but may be considered pursuant to
the Sanctions Procedures.

Symposium on Supranational Responses to
Corruption

international organizations, governments, the private sector,

In April 2022, OSD led the organization of a two-day sympo-

nizations including UNODC, the OECD, prosecutors from

sium on Supranational Responses to Corruption in Vienna,

the European Public Prosecutors Office and the UK Serious

Austria. Through its hybrid approach, 40 participants

Fraud Office, and experts from Transparency International

attended in person alongside over 300 online participants.

as well as from leading universities and research centres

The symposium brought together experts from multiple

from across the globe. The symposium’s main objective

non-governmental organizations, and academia. Speakers
included representatives from various international orga-

32 » SANCTIONS SYSTEM ANNUAL REPORT • FISCAL YEAR 2022

was to reflect on current and prospective anticorruption

establish regional/global investigative and adjudicatory

efforts that have transcended national boundaries or gov-

anticorruption institutions. The speakers discussed the

ernments. Overall, the symposium took stock of the current

establishment of the European Union’s Public Prosecutor’s

supranational anticorruption mechanisms and standards to

Office and the future of the European Union’s anticorrup-

help enhance the multiplier effect that joint learning, coor-

tion policy, the prospects of enhanced anticorruption efforts

dination, and collaboration can achieve in the fight against

based on the Inter-American Convention Against Corruption,

corruption.

and the implications of linking grand corruption to human

The symposium was co-organized with the Anti-Corruption
Law Interest Group of the American Society for International Law and the OECD’s Anti-Corruption Division. Partner
organizations included the International Anti-Corruption
Academy, the World Economic Forum’s Partnering Against

rights. The panel highlighted the need for cataloguing past
and present prosecutorial and adjudicatory regional/global
bodies to provide a comprehensive understanding of lessons
learned from such otherwise disconnected efforts, with the
goal of informing future initiatives.

Corruption Initiative, the Austrian Federal Ministry for

In the third session, the speakers analyzed how anticorrup-

European and International Affairs, and the OPEC Fund for

tion investigations, carried out by national and international

International Development.

authorities, including the World Bank and the Green Cli-

The symposium’s agenda, organized around six sessions,
was based on selected papers submitted following a call for
papers launched in the previous fiscal year, in an effort to
learn more about supranational initiatives against corruption.
Detailed information on the agenda can be found on OSD’s
website. In the introductory panel, high-level representatives
from MDBs, the private sector, government, and academia
discussed the role of their sectors in promoting integrity
and fighting corruption. The second panel explored regional
responses to anticorruption, focusing mainly on efforts to

mate Fund, work in an increasingly globalized and complex
world. The speakers discussed issues including the benefits
and challenges of negotiated resolutions, highlighting the
need for enhanced transparency and predictability, as well
as standardizations across jurisdictions. Emphasizing the
crucial importance of collaboration and knowledge-sharing
among authorities, a representative from the UNODC discussed the recently established GlobeE Network, designed
to facilitate formal and informal cooperation among national
authorities and help with capacity building.

THE OFFICE OF SUSPENSION AND DEBARMENT

« 33

The following session discussed international pathways to

in pursuit of varied efforts against corruption. The discus-

accountability for “grand corruption,” a proposed new OECD

sions highlighted both the need and interest to create more

dispute settlements mechanism to fight transnational cor-

opportunities to share knowledge and experiences with part-

ruption, the prospects of an international anticorruption

ners as we respond to significant shifts to the world. OSD is

court to address grand corruption, and the use of targeted

working on a symposium knowledge report that will be made

sanctions against foreign corruption. The fifth session

available to the public during the next fiscal year.

explored the capacities and roles that investment arbitration
tribunals should have when dealing with corruption issues.
The speakers discussed the prospects of rethinking inter-

Other Events and Outreach

national investment law’s responses to corruption through

OSD continued its outreach activities both within and out-

the prism of global governance theory and the use of a cor-

side the WBG to inform colleagues, other organizations,

ruption defense in arbitration procedures. The final session

and national governments about the mission, processes,

tackled how the non-governmental sector can play a fun-

and results of the WBG sanctions system, and to learn from

damental role in supranational anticorruption efforts. The

external stakeholders. OSD has hosted and participated in

speakers discussed the corporate legal profession’s obli-

a variety of events to discuss the sanctions system and to

gations to and opportunities for contributing to collective

promote the WBG’s broader anticorruption agenda. In FY22,

action, the power of civil society organizations that engage

OSD’s staff:

productively in influencing and supporting the design and
implementation of government-led efforts, the importance

• Co-organized with the WBG Sanctions Board Secretariat the second MDB Joint Workshop between the

of granting legal standing to non-governmental organiza-

first-tier officers and appellate body secretariats of the

tions in corruption proceedings, the operationalization of
voluntary anti-bribery management system standards, the
role of trade associations, the ethical frameworks promoted

AfDB, ADB, EBRD, IDB, and WBG.
• Co-hosted—with the George Washington Law School’s

by public-private partnerships, and collective action initia-

Government Procurement Law Program and the Amer-

tives in the healthcare field.

ican Bar Association’s International Anti-Corruption

The symposium provided a valuable opportunity to raise

& Debarment Directory. The recording of the webinar is

awareness of the WBG sanctions system, connect with and

available at https://www.youtube.com/watch?v=QMGrD-

learn from a diverse range of relevant stakeholders, and

c7DHLg.

expand the WBG sanctions system’s network at a global level
34 » SANCTIONS SYSTEM ANNUAL REPORT • FISCAL YEAR 2022

Committee—a free webinar on the Global Suspension

• Organized a virtual panel of procurement and anticorruption experts from across the WBG to discuss the
Global Suspension & Debarment Directory, the use of
exclusion as an integrity tool, and how this research can
inform WBG operations and advice to clients and borrowers.
• Following the release of the Directory, published pieces
in The FCPA Blog, an international website covering anticorruption and compliance, and on the World Bank’s
Governance for Development blog.

for each jurisdiction, and download individual summaries
from the full Directory.
The inaugural Directory revealed several interesting findings.
First, research confirmed the prevalence of exclusion systems across many countries and institutions. Indeed, only
one of the 23 jurisdictions included in the Directory did not
have any type of government-wide exclusion framework at
the national level. Second, almost all jurisdictions included
in the Directory provide an opportunity for the accused supplier to respond to or challenge the basis for its exclusion.

• The SDO participated in an interview series conducted
by the “Unspoken Giants” podcast regarding the sanctions and debarment regimes at various MDBs. The
interview with the SDO is available at https://www.rpc.

While accused suppliers generally have an opportunity to
respond, the timing of this opportunity varies widely and
does not always come before the exclusion takes effect.
Furthermore, the effect of an exclusion varies across coun-

co.uk/perspectives/unspoken-giants/.
OSD also continued to maintain regular contacts with suspension and debarment officials from national governments
and international organizations, including with its counterparts from other MDBs.

tries and organizations. A slight majority of jurisdictions
included in the Directory have a “traditional” debarment
system that prohibits offending suppliers from participating in all procurements across the government and publicly
lists the suppliers’ ineligibility. But at least eight of the summarized jurisdictions use exclusion as a basis to disqualify

The Global Suspension & Debarment Directory
In July 2021, OSD published the
Global Suspension & Debarment

offending suppliers on a contract-by-contract basis. In these
jurisdictions, the exclusions do not extend beyond a single
procurement process and are not publicly listed.

con-

The process for imposing an exclusion on an offending sup-

sultative resource on exclusion

plier also varies across jurisdictions. In certain countries, the

systems. The Directory serves as a resource for anyone

decision to exclude a supplier is made during the procure-

interested in learning how the covered countries and orga-

ment process as part of the qualification examination. In

nizations employ exclusion. Using data captured through the

others, exclusion decisions are made by independent deci-

2020 Global Suspension & Debarment Survey, the Directory

sion-makers outside the procurement process. And in other

summarizes the exclusion systems of 23 different jurisdic-

jurisdictions, both avenues are possible.

Directory, the

first-ever

tions and institutions and includes references and available
links to the relevant laws and regulations.

Perhaps the most important takeaway is that there is not
a one-size-fits-all approach when it comes to exclusion. As

The Directory presents information on six key areas for each

shown in the individual summaries, many nuances exist in

exclusion system surveyed:

the legal frameworks that made it difficult to neatly catego-

1. Government-Wide Legal and Institutional Framework
2. Functioning and Enforcement of the Government-Wide
Exclusion System
3. Substantive Grounds for Government-Wide Exclusion

rize certain jurisdictions. More research, including a deeper
dive into a select few of these jurisdictions, would help to illuminate these nuances.
The Directory was created with the support of the Debarment and Exclusions Subcommittee of the International

4. Scope and Effect of Government-Wide Exclusion

Bar Association’s Anti-Corruption Committee and the

5. Government-Wide Transparency: The Exclusion List

partnership among the World Bank’s OSD, the Sanctions

6. Limited Scope Exclusion Systems
To accompany the Directory, an interactive database has
been launched for users to sort and compare specific
aspects of the included systems, access relevant resources

Officer for the IDB Group, and Le Bureau de l’Inspecteur
General de la Ville de Montréal.
The Directory and an interactive table of jurisdictions and
their summaries are accessible online at www.worldbank.
org/exclusionsurvey.
THE OFFICE OF SUSPENSION AND DEBARMENT

« 35

Sanctions Imposed by the SDO Pursuant to Notices of Uncontested Sanctions Proceedings
During FY22, the SDO issued Notices of Uncontested Sanctions Proceedings in eight cases, resulting in sanctions
against 11 respondents for engaging in fraudulent and collusive practices in connection with Bank operations in
the public sector reform, urban infrastructure, transportation, water, and sustainable city development sectors of
client countries. All of these Notices of Uncontested Sanctions Proceedings are publicly available on the WBG’s
sanctions website. These cases included:
•

SANCTIONS CASE NO. 653—The SDO determined that the

execution. The SDO imposed on the respondent a debar-

respondent, a firm based in the Democratic Republic of

ment with conditional release for a minimum period of

Congo, engaged in fraudulent practices by misrepresent-

five years. In determining this sanction, the SDO took

ing its own experience and the experience of its proposed

into account, as aggravating factors, (i) the sophisticated

personnel in its bids for three consulting contracts under

means through which the respondent engaged in the col-

two public sector reform projects in the Democratic

lusive practice, noting that the respondent embedded two

Republic of Congo. Specifically, the SDO found that the

of its collusive partner’s employees into its operations,

respondent claimed the experience of a third party as its

acted through intermediaries, and actively misled the rel-

own in its bid for a procurement contract on secure iden-

evant project management unit to conceal the collusive

tification cards for government officials. The respondent

arrangement; and (ii) the respondent’s interference with

also partially misrepresented the experience of two of its

the investigative process, noting that the respondent pro-

proposed personnel in its bids for two consulting contracts

vided INT with a falsified document and interfered with

to support the recruitment of subject-matter experts. The

INT’s attempts to access certain email correspondence

SDO imposed on the respondent a debarment with con-

and digital records.

ditional release for a minimum period of three years and
nine months. In determining this sanction, the SDO took

•

respondent, an Uzbek firm, engaged in a fraudulent prac-

into account, as an aggravating factor, the respondent’s

tice in connection with a construction works contract

repeated pattern of misconduct, noting that the respon-

under a water supply project in Uzbekistan. In particular,

dent’s misconduct related to three contracts under two

the SDO found that the respondent misrepresented, in

different Bank-financed projects. The SDO also took into

its bid for the contract, that it did not have a conflict of

account, as a mitigating factor, INT’s representations

interest, whereas the owner and director of the respon-

regarding the respondent’s limited cooperation during

dent had a close family relationship with an individual that

the course of the investigation, noting that the respondent

served as the head of the procuring entity for the contract

responded to INT’s Show Cause Letter and provided rele-

that participated in the evaluation of the respondent’s

vant information.
•

SANCTIONS CASE NO. 702—The SDO determined that the

bid. The SDO imposed on the respondent a debarment

SANCTIONS CASE NO. 659—The SDO determined that

with conditional release for a minimum period of two

the respondent, a Vietnamese company, engaged in a

years and five months. In determining this sanction,

collusive practice in connection with its consortium bid

the SDO did not take into account any aggravating fac-

for the supply and installation of ticketing and intelligent

tors. As mitigating factors, the SDO considered (i) INT’s

transport systems for a contract under a sustainable city

representations regarding the respondent’s limited coop-

development project in Vietnam. The SDO found that

eration during the course of the investigation, noting that

the respondent entered into an improper arrangement

the respondent’s representatives met with INT and pro-

with another local firm, which had been temporarily sus-

vided some relevant information, and (ii) the significant

pended by the WBG, designed to help the ineligible firm

amount of time that had elapsed since the fraudulent

circumvent its temporary suspension and participate in

practice occurred.

the project. The respondent’s arrangement with the ineligible firm involved, among other things, embedding two

•

of the ineligible firm’s staff members in its operations,
accepting assistance from the ineligible firm to source
necessary suppliers for the contract, and expecting that
the ineligible firm would be involved in the contract’s
36 » SANCTIONS SYSTEM ANNUAL REPORT • FISCAL YEAR 2022

SANCTIONS CASE NO. 705—The SDO determined that the

respondents, two Indonesia-based companies, engaged
in fraudulent practices in the form of collusion by coordinating the pricing and drafting of their respective bids
for a contract to improve irrigation infrastructure under

a water resources and irrigation sector management

dent a debarment with conditional release for a minimum

project in Indonesia. The SDO imposed on one respon-

period of six years. In determining this recommended

dent a debarment with conditional release for a minimum

sanction, the SDO took into account, as aggravating fac-

period of one year and seven months. In determining

tors, (i) the corporate respondent’s repeated pattern of

this recommended sanction, the SDO took into account,

fraudulent practices involving multiple misrepresenta-

as mitigating factors, (i) the significant passage of time

tions regarding the company’s past experience across

since the misconduct occurred and since the Bank

four bids, and (ii) the involvement of the corporate

became aware of it, and (ii) the respondent’s coopera-

respondent’s Director in the misconduct. On the indi-

tion during the course of the investigation, noting that the

vidual respondent, the SDO imposed a debarment with

respondent’s representatives agreed to be interviewed

conditional release for a minimum period of five years. In

and acknowledged that the respondent had collabo-

determining this recommended sanction, the SDO took

rated with another bidder on their bids for the relevant

into account, as aggravating factors, (i) the individual

contract, although the representatives did not ultimately

respondent’s repeated pattern of fraudulent practices

accept responsibility or admit that the collusive practice

involving multiple misrepresentations regarding the cor-

had occurred. The SDO imposed on the other respon-

porate respondent’s past experience across two bids,

dent a debarment with conditional release for a minimum

and (ii) the fact that the individual respondent was the

period of two years. In determining this recommended

Director of the corporate respondent.

sanction, the SDO took into account, as a mitigating factor, the significant passage of time since the misconduct

•

respondent, an Iranian firm, engaged in a fraudulent prac-

occurred and since the Bank became aware of it.
•

tice in connection with a road construction contract under

SANCTIONS CASE NO. 712—The SDO determined that

an infrastructure development project in Kazakhstan.

the respondents, two Uzbekistan-based companies,

The SDO found that the respondent submitted fraudu-

engaged in fraudulent practices by misrepresenting

lent performance and advance payment securities to the

their past experience in their consortium bid for a sew-

relevant project implementing unit. The SDO imposed

erage networks and pumping station works contract

on the respondent a debarment with conditional release

under a water, sanitation, and waste management proj-

for a minimum period of three years and four months. In

ect in Uzbekistan. In particular, the SDO found that one

determining this sanction, the SDO took into account, as

respondent misrepresented that it had previously com-

an aggravating factor, the degree of harm to the project

pleted a US$16.2 million construction contract, and the

arising from the respondent’s conduct, noting in particu-

other respondent misrepresented that it had previously

lar that the respondent’s misconduct caused substantial

completed a US$9.8 million construction contract. The

delays to the project. As a mitigating factor, the SDO took

SDO imposed on one respondent a debarment with con-

into account the passage of time since the misconduct

ditional release for a minimum period of three years. In

occurred and since the Bank became aware of it.

determining this recommended sanction, the SDO did
not apply any aggravating or mitigating factors. The SDO
imposed on the other respondent a debarment with conditional release for a minimum period of two years and
10 months. In determining this recommended sanction,
the SDO took into account, as a mitigating factor, evidence of the respondent’s limited voluntary corrective
action, noting that the respondent informed INT that it
had convened a meeting of its founders after receiving
INT’s Show Cause Letter and decided to terminate the
contracts of several individuals.
•

SANCTIONS CASE NO. 726—The SDO determined that the

•

SANCTIONS CASE NO. 753—The SDO determined that the

respondent, a Vietnamese firm, engaged in a fraudulent
practice in connection with a public transportation contract under an urban infrastructure development project
in Vietnam. The SDO found that the firm omitted, from its
bid in a joint venture with a foreign company, its intent to
subcontract more than 10% of the contract’s total work
volume to another company. The SDO imposed on the
respondent a debarment with conditional release for a
minimum period of two years and 10 months. In determining this recommended sanction, the SDO took into

SANCTIONS CASE NO. 720—The SDO determined that

account, as a mitigating factor, the respondent’s limited

the respondents, an Azerbaijan-based company and an

cooperation during the course of the investigation, noting

Azerbaijani national, engaged in fraudulent practices

that the respondent’s representatives met with INT and

by misrepresenting past experience in multiple bids for

provided some relevant information but did not accept

construction contracts under a water supply project in

responsibility for the misconduct.

Uzbekistan. The SDO imposed on the corporate responTHE OFFICE OF SUSPENSION AND DEBARMENT

« 37

The Sanctions Board continues to resolve all
contested sanctions cases fairly, transparently,
and expeditiously—thereby ensuring the highest
standards of accountability within
WBG-financed projects.

38 » SANCTIONS SYSTEM ANNUAL REPORT • FISCAL YEAR 2022

The WBG Sanctions Board
The second and final tier of the WBG’s adjudicative sanctions system

Introduction by
Giuliana Dunham Irving,
Executive
Secretary to the
WBG Sanctions Board
This past year was marked by

and in-person formats for the conduct of Sanctions Board
deliberations and hearings. In doing so, the Sanctions Board
continues to resolve all contested sanctions cases fairly,
transparently, and expeditiously—thereby ensuring the
highest standards of accountability within WBG-financed
projects.

renewal and new energy—with

In this annual report, in addition to sharing key statistics

the Sanctions Board and Sec-

and outcomes, we introduce our new Sanctions Board

retariat emerging from the waning pandemic stronger than

Chair and newest member and provide an overview of the

ever. Most notably, we welcomed the appointment of a new

Sanctions Board’s core work program. We also take a closer

Sanctions Board Chair. We benefited tremendously from the

look at two areas of jurisprudence addressed by the Sanc-

steady leadership of Mr. John Murphy during his tenure. And

tions Board in its decisions this year. First, we examine the

we are so lucky that his successor, Ms. Maria Vicien Milburn,

Sanctions Board’s treatment of “rogue employee” defenses

has so ably stepped into the role since her appointment.

to liability. Second, we highlight decisions that define the

I would be remiss if I failed to mention that Ms. Milburn is

bounds of disclosure obligations relating to payments

the first woman to Chair the Sanctions Board since it was

to agents. We conclude with a summary of key facts and

fully constituted in 2007. Ms. Milburn’s selection has further

takeaways from the Sanctions Board’s most recent set of

enhanced the diversity and credibility of the sanctions sys-

published decisions.

tem and we look forward to the year ahead with her at the
helm of the Sanctions Board.

We hope this section of the report helps to illustrate the

Another driver of renewal and new energy this past year

position, transparency, and case law—to the fairness and

has been the Secretariat’s transition to a hybrid operating

credibility of the sanctions system and the WBG’s fight

model. We continue to leverage the new technologies and

against corruption around the world.

skills developed during the pandemic for a mix of virtual

Sanctions Board’s central contributions—through its com-

Giuliana Dunham Irving

Executive Secretary to the WBG Sanctions Board

THE WBG SANCTIONS BOARD

« 39

Who We Are
The WBG Sanctions Board is an independent administra-

Sanctions Board Members

tive tribunal that serves as the sanctions system’s second

The Sanctions Board is composed of seven members, who

and final tier of review for contested sanctions cases. The

are nominated by the WBG President and appointed by the

Sanctions Board issues non-appealable decisions in sanc-

WBG Boards of Executive Directors. Sanctions Board mem-

tions cases arising from projects financed, co-financed,

bers serve single, non-renewable terms of up to six years.

or guaranteed by any member institution of the WBG. In

They act as impartial decision-makers, are all external to the

addition, the Sanctions Board reviews other types of cases,

WBG, and are subject to disclosure obligations and conflicts

including disputes regarding the scope of sanctions and

of interest rules. Candidates for membership are identi-

compliance with conditions for release from sanction. The

fied by the World Bank, IFC, or MIGA—with the World Bank

Sanctions Board considers sanctions cases in dedicated

selecting three members (including the Chair), and IFC and

three-member panels or as a five-member plenary group.

MIGA each selecting two members. Candidates must satisfy

The Sanctions Board has issued more than 137 decisions

requirements of professional expertise and independence. In

to date and, since 2012, has published all final and fully-rea-

cases involving IFC or MIGA financing, the Sanctions Board

soned decisions online.

may also receive input from an internal advisor appointed by
the relevant institution.

Sanctions Board Members

Maria Vicien Milburn
Sanctions Board Chair
(World Bank)
Argentina, Spain
In FY22, the Sanctions
Board welcomed a new
Chair and filled the post
vacated by Mr. Mark
Kantor (term completed
in 2021). As reflected
here, the new Sanctions
Board Chair is Ms. Maria
Vicien Milburn, and the
new member is
Mr. Michael Ostrove.

Rabab Yasseen
Member
(World Bank)
Switzerland

John R. Murphy
Member
(World Bank)
South Africa

Adedoyin Rhodes-Vivour
Member (IFC)
Nigeria

Cavinder Bull
Member (IFC)
Singapore

Michael Ostrove
Member (MIGA)
France, United States

Eduardo Zuleta
Member (MIGA)
Colombia

40 » SANCTIONS SYSTEM ANNUAL REPORT • FISCAL YEAR 2022

In FY21, the Sanctions Board filled two posts vacated
by Mr. Alejandro Escobar and Ms. Olufunke Adekoya
(terms completed in 2020). The new members, as

Sanctions Board Secretariat

In addition to regular staff, the Secretariat’s FY22 team

The Sanctions Board Secretariat provides legal, strategic,

included an associate from the WBG-Howard University Law

and administrative support and advice to the Sanctions

School program. The program places law students in WBG

Board. The Executive Secretary to the Sanctions Board

units addressing issues of integrity and internal justice at the

oversees the Secretariat’s work program, leading a diverse

institution and brings students with backgrounds and interest

team of attorneys and support staff. Among other functions,

in alternative dispute resolution. During FY22, the Secretariat

the Secretariat assists the Sanctions Board in reviewing

welcomed Mr. Edward Obinna Nwaba (United States).

cases, issuing decisions, holding hearings, convening for
deliberations, and liaising with relevant stakeholders within
the WBG and in the international development community.

What We Do

The Secretariat also plays a key role in sanctions policy dis-

Review of Contested Sanctions

cussions, and actively engages in strategic outreach and

Cases

knowledge sharing to ensure that the lessons learned from

The Sanctions Board provides a full,

the Sanctions Board’s work are integrated into the WBG’s

fair, and independent review of all

operational work.

sanctions cases where the respondent

The diversity of the Sanctions Board is mirrored in the Secretariat. The Secretariat includes seven team members, the
majority of whom are women and include two members of
the LGBTQ+ community. Secretariat staff come from Brazil,
Italy, the Philippines, Russia, and the United States. Members of the Secretariat have diverse experiences in WBG
institutional administration and operations, U.S. federal
prosecutions, judicial clerkships, corporate and criminal
litigation, international dispute resolution, white collar investigations, international law, international development, and
program management

contests the allegations made by INT

33%

Proportion of
respondents that
contested cases
to the Sanctions
Board in FY22.

and/or the sanction recommended
by any of the WBG’s first-tier officers. In its review of contested sanctions cases, the Sanctions Board applies a “more
likely than not” standard of proof. This standard means that,
upon consideration of all the relevant evidence, a preponderance of the evidence supports a finding that the respondent
engaged in a sanctionable practice. The Sanctions Board
carries out its analysis under a “burden-shifting” framework
in which INT bears the initial burden of proof to present sufficient evidence of misconduct. Upon such a showing by INT,

FIGURE 15: Trend in the Type of Misconduct Alleged in Cases Contested to the Sanctions Board (by Case) (FY18–FY22)

9
8

Number of Cases

7
6
5
4
Fraud

Corruption

Collusion
Obstruction

1
0
FY18

FY19

FY20

FY21

FY22

Fiscal year

THE WBG SANCTIONS BOARD

« 41

New Sanctions Board Chair and Member Profiles
MARIA VICIEN MILBURN, the new Sanctions Board Chair, has broad experience as a high-level international
lawyer in the UN system—having served as General Counsel of UNESCO and as Director of the General Legal
Division of the UN Legal Office, among other senior roles. Presently, Maria is a judge and arbitrator in the context
of disputes of an international character. She has been appointed to serve on numerous international adjudicative
bodies—including the Administrative Tribunals of the International Monetary Fund, the EBRD, and the IDB. In addition, Maria was designated on the list of panelists of the Dispute Settlement Body of the WTO.
What inspired you to serve on the Sanctions Board?
During my years as a senior legal advisor within the UN
system, I provided advice on issues arising from alleged
corruption in public procurement. In connection with the
Oil-for-Food Programme, and after the issuance of the
Independent Inquiry Report chaired by Paul Volcker, I was
directly responsible for the UN’s cooperative activities with
national authorities prosecuting those who had allegedly
engaged in corrupt practices under the auspices of the Programme. In these contexts, I witnessed the pervasiveness of
the “cancer of corruption” and its deleterious effects on the
UN system, Member States, and the delivery of public goods
and services. This is a shocking problem with global reach
and massive economic and social costs. Clearly, corruption
is a major impediment to development. It diverts scarce
development funds from those who most desperately need
them—while illicitly enriching the corrupt actors. I have a visceral disdain for all forms corruption and firmly believe that
no public money should ever be made available to sustain
corrupt conduct. I see my work on the Sanctions Board as
a continuation of my contributions to the fight against corruption that I began some decades ago at the UN. This is an
important institution that provides a powerful platform—
through its detailed public decisions—to signal to the world
that we will fight corruption wherever we find it.

How does diversity impact the work of the Sanctions
Board?
I must begin by saying that I am so delighted to have been
nominated by the President of the Bank to serve as Sanctions
Board Chair. I understand that I am the first woman to be
elevated to this role since the Sanctions Board was fully constituted 15 years ago. While I would have hoped that a woman
might have led this institution sooner, I applaud the President
and the Board of Directors for showing their commitment
to diversity. As a practicing international lawyer for over 40
years, I understand the importance of diversity—and I know
so much more needs to be done on this front. During my UN
service, I worked very hard to create a diverse environment,
including by fighting to achieve a 50/50 balance of men and
women lawyers in my office. I did this because I know that
diverse and inclusive groups are more innovative and critical
than their more homogenous counterparts. I have observed
this first-hand with the Sanctions Board, which represents
a wide diversity of nationalities, backgrounds, and experiences. We constantly challenge each other to see issues from
all angles and perspectives in a way that I know results in
nuanced, balanced, and judicious outcomes for the parties.
Our diversity is among our greatest strengths.

MICHAEL OSTROVE, the Sanctions Board’s newest member, is the Global Co-Chair of DLA Piper’s International
Arbitration group and a Vice-President of the ICC International Court of Arbitration. A member of both the Paris
and New York bars, he has over 25 years’ experience handling international arbitrations, public international law
disputes, domestic litigation, and corruption investigations. Michael acts routinely for sovereign states, multinational corporations, international organizations, and individuals. His arbitrations have involved a variety of sectors,
including mining, oil and gas, pharmaceuticals, infrastructure, agriculture, telecoms, and distribution. His litigation
experience includes cases before national courts, the International Court of Justice, and the Court of Justice of the
European Union. Michael teaches international arbitration at the University of Paris II. He is ranked by Chambers as
a Global Market Leader for International Arbitration and has been repeatedly recognized by Jeune Afrique as among
the most influential lawyers working in francophone Africa.
What inspired you to serve on the Sanctions Board?
I have seen how fraud and corruption undermine development. I have also seen the important role that the World
Bank Group plays in ensuring development in accordance
with the rule of law. I was definitely inspired by the opportunity to participate in an essential part of the World Bank
Group’s integrity system—one that at the same time
ensures the fair treatment of all participants.

What lessons can the private sector learn from Sanctions Board precedent?
The transparency of the Sanctions Board system allows private sector actors to become more acutely aware of the many
types of fraud, collusion, and corruption that can arise in Bank
Group-supported transactions. This can allow the private sector not only to ensure that their compliance programs take into
account the reality on the ground, but also to benefit from concrete examples of the consequences of compliance failures.

42 » SANCTIONS SYSTEM ANNUAL REPORT • FISCAL YEAR 2022

Pictured: WBG Sanctions Board Secretariat (from left to right): Felipe Rocha dos Santos, Counsel; Amanda Schneider, Legal
Assistant; Giuliana Dunham Irving, Executive Secretary to the Sanctions Board; Ryan Velandria McCarthy, Senior Counsel;
Anna Lorem Ramos, Counsel (Not pictured: Geise Santos, Program Assistant).

Sanctions Board Secretariat Staff & Consultants At-A-Glance

STAFF &
CONSULTANTS

FROM

SPEAKING

COUNTRIES

LANGUAGES

71%

FEMALE

29%
MALE

the burden of proof shifts to the respondent to show that

clusions on liability and appropriate sanctions as compared

INT’s allegations are not supported by a preponderance of

to the first-tier officers.

the evidence.10 Between FY18–FY22, the Sanctions Board
reviewed and decided 39 contested sanctions cases against
56 respondents.

Among all cases contested during the FY18-FY22 period, the
Sanctions Board held 98% of those respondents liable for
alleged misconduct. For 2% of the respondents during the

The Sanctions Board hears cases de novo, which means

same period, the Sanctions Board concluded that the record

that it reviews each case anew without deference to deter-

did not support a finding of liability and terminated the pro-

minations reached at the first tier of the sanctions process.

ceedings without any sanction.

In reviewing contested cases, the Sanctions Board considers a more expansive record than at the first tier, including
at least one further round of written pleadings containing
additional arguments and/or new evidence, and an oral
hearing if requested by either party or called by the Sanctions Board Chair. In addition, the Sanctions Board makes
determinations on any jurisdictional, evidentiary, and procedural issues not resolved at earlier points in the process.
As a result, the Sanctions Board may reach different con-

In contested cases where the Sanctions Board reaches
a finding of liability, it conducts an analysis of all relevant
aggravating and mitigating factors in selecting the appropriate sanction. During the FY18–22 period, sanctions
applied by the Sanctions Board “matched” those at the
first tier in 9% of instances. For 54% of contesting respondents, the Sanctions Board applied a sanction that included
a lesser period of minimum debarment. For 36% of contest-

THE WBG SANCTIONS BOARD

« 43

ing respondents, the minimum debarment period imposed

disregard of a material fact or a material mistake of fact, or

by the Sanctions Board was greater.11 For the remaining 2%

(iii) was taken in material violation of applicable procedures.

of respondents, as noted above, the Sanctions Board found
insufficient evidence of misconduct and did not, therefore,
impose any sanction. This variance in decision outcomes
between the first tier and the Sanctions Board is reflective
of a well-functioning quasi-adjudicative system where the
second tier reviews an extended case record. Where misconduct is found, the Sanctions Board generally applies a
broad range of sanctions, including debarment with conditional release, conditional non-debarment, debarment for
a fixed period of time, and letters of reprimand. The conditions applied by the Sanctions Board are similarly varied
and tied to the facts of each case and the risk attendant to
the misconduct at issue.
Review of Other Types of Cases
In addition to resolving contested sanctions cases, the Sanctions Board is responsible for reviewing four other types of
disputes. First, the Sanctions Board reviews cases where a
sanctioned party contests the Integrity Compliance Officer’s
determination that the party did not comply with conditions
for release from sanction. Second, the Sanctions Board
reviews appeals from parties that entered into settlement
agreements with the Bank, as negotiated by INT. In such
cases, the sanctioned party may contest INT’s subsequent
determination of non-compliance with the conditions of
the settlement or seek to resolve any controversy as to the
interpretation or performance of the settlement’s terms and
conditions. Third, where the WBG designates an entity as a
respondent’s successor or assign and extends the respondent’s sanction to that entity,12 that entity may appeal the
WBG’s determination to the Sanctions Board.

Fourth, the Sanctions Board may review requests for reconsideration of Sanctions Board decisions. The Sanctions
Board has held that such a request would be granted only
in narrowly defined and exceptional circumstances. These
circumstances include discovery of newly available and
decisive facts, fraud in the original proceedings, or clerical
mistake in the issuing of the original decision.
Conduct of Hearings
Sanctions Board hearings are confidential and informal. They may be
convened at the request of the respondent or INT, or at the discretion of
the Sanctions Board Chair. Hearings

Cases with oral
hearing (FY22):

25%

begin with opening presentations,
with INT presenting its case first and
the respondent afterwards. INT is then
permitted to reply to the respondent’s
opening presentation. The Sanctions
Board

members

thereafter

pose

Cases involving
outside counsel:
(FY22):

50%

questions to the parties. In certain circumstances, the Sanctions Board may call witnesses, who
may be questioned only by Sanctions Board members. The
parties do not have the right to directly question or cross-examine witnesses. At the conclusion of a hearing, the parties
are invited to make closing presentations, with the respondents being given the opportunity to have the last word.
Issuance of Sanctions Board Decisions
Consistent with the WBG’s commitment to transparency, the Sanctions

In reviewing these three types of disputes, the Sanctions

Board is a leader among MDBs as the

Board uses an “abuse of discretion” standard and ascer-

first sanctions body to publish its ful-

tains whether the WBG determination at issue (i) lacked an

ly-reasoned decisions in all types of

observable basis or was otherwise arbitrary, (ii) was based on

appeals. Sanctions Board decisions

In FY22,
firms
and individuals
were sanctioned
by the
Sanctions Board

set out detailed factual and legal
» Appeals of ICO determinations

analyses, procedural and substantive findings, and citations
to relevant precedent. The holdings in unpublished decisions
between 2007 and 2011 were presented in the first edition

» Appeals of settlement compliance determinations

of the Sanctions Board’s Law Digest, issued in December
2011. The shift to public Sanctions Board decisions in 2012
has resulted in the development of a body of jurisprudence

» Appeals by designated successors and assigns

that offers guidance to international stakeholders involved in
anticorruption and administrative sanctions. The full body

» R
equests for reconsideration of Sanctions Board
decisions

of Sanctions Board precedent as of FY19 is presented in the
second edition of the Law Digest.

44 » SANCTIONS SYSTEM ANNUAL REPORT • FISCAL YEAR 2022

Vicarious Liability and the “Rogue Employee” Exception
As a rule, corporate respondents may be held vicar-

in question acted in contravention of specific corporate

iously liable for the acts of their owners, staff, and

policies (i.e., the “rogue employee” defense). Under

authorized representatives pursuant to the doctrine

Sanctions Board precedent, for this exception to apply,

of respondeat superior. Under this standard, the

the record must show that the respondent firm had

Sanctions Board has consistently imposed sanctions

implemented internal controls reasonably sufficient to

against companies in cases where the culpable employ-

prevent or detect the sanctionable practices at issue;

ees were acting within the course and scope of their

that the employee nevertheless evaded such controls;

employment and were motivated, at least in part, by

and that the respondent firm meaningfully disciplined

a purpose to serve their employer. The relevant ques-

the employee for the misconduct. Consistent with such

tion here is not whether the misconduct was condoned

standards, this year, the Sanctions Board rejected a

by the employer, but whether it was a mode (albeit

respondent firm’s “rogue employee” defense in the

improper) to carry out the employee’s responsibili-

case resolved by Decision No. 137 (discussed further

ties. Accordingly, this doctrine does not require proof

below). Notably, while the Sanctions Board found that

that the company specifically authorized, approved,

some internal controls were in place at the time of the

or even knew of the misconduct by the employee. This

misconduct, the record contained insufficient evidence

notwithstanding, respondent firms may be exempted

showing that the respondent firm enforced them in a

from liability where they can prove that the employee

meaningful way.

FIGURE 16: Type of Sanctions Imposed on the

Respondents by the Sanctions Board (FY18–FY22)

FIGURE 17: Number of Decisions Issued by the Sanctions
Board (FY18–FY22)

18
6%

27%
67%

Number of Decisions

1
1

12
10
8
6

4
Debarment with conditional release
Debarment without conditions
Letter of reprimand

2
0

FY18

FY19

FY20

FY21

FY22

Decision in successor appeal
Decisions in requests for reconsideration
Decisions in contested cases
* Some decisions resolve more than one contested case. For example,
where the Sanctions Board has joined related cases for efficiency
and fairness.
** During the period of FY18–FY22, the Sanctions Board issued a
decision every 44.5 days, on average

THE WBG SANCTIONS BOARD

« 45

Defining the Scope of Disclosure Obligations Related to Agents
Bidding documents for WBG-financed contracts gen-

sure requirement established in the bidding documents

erally require bidders to make an array of disclosures.

is to “help reveal and deter potentially corrupt relation-

Where a bidder fails to make a requisite disclosure, the

ships in Bank-Financed Projects.” Referencing its past

bidder risks subjecting itself to possible sanctions for

precedent, the Sanctions Board further observed that

fraud. This year, the Sanctions Board resolved a dispute

“the risk of corrupt relationships arises not only when a

between INT and a respondent regarding the propri-

principal-agent relationship exists between a bidder and

ety of the respondent’s non-disclosure of payments to

a third party, but whenever a bidder pays a commission

a third party. In that case, resolved in Decision No. 136

or gratuity to a third party in relation to the contract.” The

(discussed further below), INT argued that the respon-

Sanctions Board noted that a narrow reading of the term

dent engaged in fraud because he knowingly failed to

“agent” would be inconsistent with this underlying pur-

disclose commissions paid to an agent in connection

pose of the disclosure obligation. By clarifying the scope

with the World Bank procurement process in question.

of the respondent’s disclosure obligations, the Sanc-

The respondent argued, inter alia, that he did not con-

tions Board enhances the Bank’s ability to scrutinize

sider the firm to be a “simple sales agent” requiring

those who might participate in, or benefit from, Bank-fi-

disclosure. In rejecting the respondent’s defense, the

nanced projects—while at the same time transparently

Sanctions Board explicitly declined to adopt the narrow

highlighting where non-disclosures may constitute a

reading of the term “agent” implicit in the respondent’s

fraudulent practice.

argument—observing that a key purpose of the disclo-

Knowledge Sharing and Engagement with
Stakeholders

tions Board to entertain and resolve requests for interim
expedited relief. In another piece, the Secretariat highlighted that the sanctions imposed by the Sanctions

In addition to resolving contested sanctions cases, the Sanc-

Board are fair and proportionate—focusing on instances

tions Board recognizes the value of knowledge sharing and

where debarment may be appropriate for fraud.

engagement with the global anticorruption community. To
that end, this past year, the Sanctions Board and the Secretariat provided internal consultations to WBG management

• Second MDB workshop between first-tier officers and

on the functioning of the WBG sanctions system, engaged in
dialogue with peers at other international development organizations, and participated in public forums focused on the
fight against corruption in development.
• Publications in a leading industry forum
Continuing its role as a thought leader among global
anticorruption practitioners, the Secretariat authored
timely pieces that were published on The FCPA Blog,
a widely read international forum for commentary on
anticorruption. In one piece, the Secretariat imagined
hypothetical scenarios where a party requests that the
Sanctions Board conduct an expedited review of a matter or grant provisional relief—even though the Sanctions
Procedures do not explicitly contemplate such mechanisms. The Secretariat then discussed how the Sanctions
Framework may already be flexible enough for the Sanc-

46 » SANCTIONS SYSTEM ANNUAL REPORT • FISCAL YEAR 2022

appellate body secretariats
The Secretariat organized, with OSD as its partner, the
second MDB workshop between the first and second
tiers of the sanctions systems at the AfDB, ADB, EBRD,
IDB, and WBG. The workshop covered a range of areas
of mutual interest and provided an opportunity for the
world’s major development institutions to learn from
each other’s experiences and practices. Discussion topics included additional areas for harmonization across
the institutions, potential new signatories to the MDB
Cross-Debarment Agreement, and imposition of permanent debarments on respondents.

• IDB-hosted Conference of MDB Sanctions Appeals

• ICC Sanctions Module

Bodies

On May 31, 2022, the Executive

The Sanctions Board and Secretariat

Secretary opened the Interna-

actively participated in the Conference

tional Chamber of Commerce

of MDB Sanctions Appeals Bodies, which was hosted by

(ICC) Institute of World Business

the IDB this past year. Over the course of the two-day

Law’s first online module of the

conference, participants engaged in active plenary and

newly established ICC Institute

small group discussions, listened to expert lectures, and

SME Lab on Compliance. In this online module, “Introduc-

participated in mock deliberations. Among other topics,

tion to Trade Sanctions,” the Executive Secretary aimed

participants discussed expedited sanctions proceedings,

at providing guidance to small and medium enterprises

extension of sanctions to affiliated companies of corpo-

by explaining the nature of economic sanctions and

rate groups, and trends in the selection of sanctions for

trade restrictions, examining their impacts on SMEs, and

misconduct. The conference also provided an opportu-

exploring practical ways to ensure compliance and miti-

nity for members of the various MDB Sanctions Appeals

gate risks.

Bodies to informally network with each other and share
case-related experiences.
• Graduate course on corruption risk mitigation

Summary of Precedent in FY22
During FY22, the Sanctions Board issued four decisions

The Secretariat worked with

(Sanctions Board Decisions No. 134–No. 137) arising from

the

University

contested cases that were reviewed in Fall 2021 and Spring

Washington College of Law

2022. The cases were diverse in scope and involved alle-

in coordinating a graduate

gations of fraud, corruption, and obstruction relating to

course on the mitigation of corruption risks in public

contracts financed by IBRD, IDA, and the Strategic Climate

procurement, which enrolled legal and public policy prac-

Fund. The projects at issue sought to develop the financial

titioners from Armenia, Colombia, Ecuador, Georgia,

capacity, health, infrastructure, and water sectors of several

Lebanon, Liberia, Mexico, the Philippines, and the United

countries including Kenya, Romania, and Vietnam.

American

States. The course, which sought to review WBG-specific measures against corruption in public procurement,

The Sanctions Board’s findings and conclusions, as describ-

forms part of a larger program focusing on anticorrup-

ed below, were reached pursuant to the “more likely than not”

tion law and practice. This knowledge-building initiative

standard of proof. The Sanctions Board’s findings relied on a

brought together diverse participants from the Bank’s

diverse array of evidence submitted by the parties, including

anticorruption agenda, including colleagues from the

copies of contemporaneous correspondence, testimonial

Governance Global Practice, Operations, Procurement,

evidence from interviews conducted by INT investigators,

INT, OSD, and the ICO.

and documentation of transactions relevant to each case.

In September 2021,the Secretariat launch-

Fraudulent misrepresentations relating to personnel’s
experience and obstruction of a Bank audit:

ed its inaugural newsletter—“Sanctions

DECISION NO. 134. In this decision, the Sanctions Board

Board Insights”—which the Secretariat

imposed sanctions of debarment with conditional release

plans to publish bi-annually going for-

on two respondent firms, for a minimum period of six years

ward. This new publication provides readers with regular

each. The first firm was part of a joint venture that won three

updates on Sanctions Board membership changes, key

contracts financed by the Bank under the Project Prepara-

case statistics, and relevant sanctions policy develop-

tion Technical Assistance Facility Project and the Da Nang

ments. In addition, the newsletter features an overview

Sustainable City Development Project in Vietnam. The

of recently issued Sanctions Board decisions—setting

second firm was named as a subcontractor or authorized

out key findings and highlighting any particularly novel

representative of the first firm in each of these contracts.

• Sanctions Board Newsletter

or interesting aspects of the cases. Subscribers can sign
up for the newsletter at https://www.worldbank.org/en/
newsletter-subscription.

Allegations, evidence, and findings: INT alleged that both
respondents misrepresented the experience of key experts
in two proposals and related contracts, and that the first firm
obstructed a Bank audit by concealing evidence and impedTHE WBG SANCTIONS BOARD

« 47

ing INT’s review of pertinent books and records. With respect

Bank investigation, including by making false statements

to the first accusation, the respondents did not dispute the

and submitting forged evidence to INT’s investigators. Tes-

alleged misrepresentations, and the record reflected the

timonial and documentary evidence revealed that, contrary

involvement of both firms’ staff in the preparation of the

to express contractual provisions, the respondent engaged

proposals. While the respondents denied acting with the

several subcontractors without seeking or obtaining proper

requisite intent, testimonial and documentary evidence indi-

authorization; and made concerted efforts to conceal or

cated that the second firm’s staff knowingly included false

disguise the true nature of these relationships from the

information in the proposals; and that the first firm’s staff

relevant authorities, including by mischaracterizing the sub-

acted at least recklessly in certifying the authenticity of the

contractors as suppliers. The respondent argued that this

information in question without any verification or oversight

subcontracting was public and that the relevant authorities

and in submitting the proposals to the relevant government

were involved in this arrangement, including by instructing

agency. With respect to the obstruction accusation, the first

the respondent to hire specific subcontractors and by assist-

firm argued that it did not refuse INT’s audit, but rather was

ing the respondent in settling disputes with the companies

unable to locate or produce documents that were not in its

in question. The Sanctions Board was not persuaded by

possession. However, the record showed that the first firm’s

this defense, seeing no evidence that the relevant authori-

representatives intended to impede the audit, including

ties had any knowledge of the subcontractors prior to their

by producing incomplete materials despite INT’s detailed

engagement. In addition, the record showed that, during

requests, failing to cooperate during interviews, and con-

interviews with INT, the respondent’s staff misrepresented

cealing material evidence. The Sanctions Board found both

the respondent’s relationship to one of the subcontractors,

respondents liable for fraudulent practices, and the first firm

by claiming that the subcontractor’s owner was the respon-

liable for an obstructive practice.

dent’s employee. Evidence also revealed that the respondent

Sanctioning analysis: In its sanctioning analysis, the Sanctions Board applied aggravation for both respondents’
repeated pattern of misrepresentations and lack of candor
in the proceedings. The Sanctions Board applied additional
aggravation for the severity of the second firm’s involve-

produced forged employment records to support such false
claims, and attempted to induce the subcontractor’s owner
to fabricate additional documents for submission to INT. The
Sanctions Board found the respondent liable for fraudulent
and obstructive practices.

ment in the fraudulent practices (central role, participation

Sanctioning analysis: In its sanctioning analysis, the Sanc-

of senior management, mode of misconduct) and for the

tions Board applied aggravation for the sophisticated

first firm’s interference with the Bank’s audit. The Sanctions

nature of the misconduct and for the involvement of the

Board granted both respondents some mitigation for the

respondent’s senior personnel. Considering the finding of

passage of time since the misconduct. The Sanctions Board

obstruction, the Sanctions Board declined to grant any miti-

declined to apply any credit for asserted factors that were

gation for the respondent’s cooperation.

either unsupported by the record (minor role, internal action,
changes in management) or unrelated to the respondents’

Corruption and fraudulent misrepresentation for failureto disclose payments to an agent:

culpability or responsibility for the misconduct (absence of

DECISION NO. 136. In this decision, the Sanctions Board

harm or history of misconduct).

imposed a sanction of debarment for a period of two years

cessation of misconduct, cooperation, compliance program,

on a respondent individual. The respondent was the managFraudulent misrepresentation for failure to disclose subcontractors and obstruction of a Bank investigation:

ing director of a company that won a Bank-financed contract

DECISION NO. 135. In this decision, the Sanctions Board

Preparedness and Response Project in Romania.

imposed a sanction of debarment with conditional release
for a minimum period of six years and six months on the
respondent firm. The respondent won a contract to build
three primary schools under the Mekong Delta Region Urban
Upgrading Project in Vietnam.
Allegations, evidence, and findings: INT alleged that the
respondent failed to disclose certain subcontractors during
the implementation of the contract and also impeded a

under the Avian Influenza Control and Human Pandemic

Allegations, evidence, and findings: INT alleged that the
respondent made a corrupt payment to a Bank consultant
through an intermediary, in order to influence the award of
the relevant contract. INT also alleged that the respondent
failed to disclose commissions to an agent in his company’s
bid. With respect to the first accusation, the respondent
admitted to paying a percentage of the contract to an intermediary but denied being aware that any amounts would be

48 » SANCTIONS SYSTEM ANNUAL REPORT • FISCAL YEAR 2022

transferred to the Bank consultant. However, the respon-

Instead, the respondents asserted that the consultant and

dent himself had stated during INT’s investigation that the

a former employee had prepared the bids and engaged in

purpose of the payment was to ensure that the Bank con-

the misrepresentations in question, in violation of clear

sultant would not cause undue delays in the procurement

instructions and company policy. The respondents further

process. In addition, the Sanctions Board concluded that the

argued that the respondent individual had relied on the

circumstances of the payment, including its close time prox-

work of the consultant and former employee and signed the

imity to the signature of the contract, further demonstrated

documents without any supervision or verification. How-

the respondent’s corrupt intent. With respect to the second

ever, the totality of the evidence, particularly considering

accusation, the respondent conceded that his company had

the circumstances and nature of the misrepresentations,

paid a commission to a third party and that he signed the

indicated that the respondents intended to mislead the

company’s bid without disclosing this information. Never-

relevant authorities. For example, the respondents signed

theless, the respondent argued that this payment was not

the consultancy agreement and made the undisclosed

subject to disclosure because the third party did not act

payment in close time proximity to the submission of the

as his company’s agent. The Sanctions Board rejected this

bids—indicating knowledge of the fraudulent omission.

defense, noting that the respondent’s reading of the term

Alternatively, documents showed that the respondent firm

“agent” was too narrow and that, in any case, the applica-

had previously identified the risk that the consultant might

ble disclosure requirements comprised payments to any

make misrepresentations on the respondent firm’s behalf,

firms or individuals. With respect to both accusations, the

yet the respondents admittedly failed to implement any

respondent raised that he, his company, and others had

controls to mitigate this risk—indicating at least reckless-

been exonerated in national legal proceedings relating to the

ness. The respondents also argued that the respondent

same facts. The Sanctions Board was unpersuaded, noting

firm was responsible neither for the acts of the consultant,

that national law standards and judgments are not binding

who was an independent contractor, or for those of the for-

on the Bank. The Sanctions Board found the respondent lia-

mer employee, who purportedly acted as a rogue employee.

ble for corrupt and fraudulent practices.

The Sanctions Board found the respondent firm responsi-

Sanctioning analysis: In its sanctioning analysis, the Sanctions Board applied aggravation based on the respondent’s
sophisticated means of misconduct, and mitigation for the
significant passage of time since the relevant events. The
Sanctions Board declined to apply aggravation for repetition, management’s role, involvement of a public official,
and lack of candor.
Fraudulent misrepresentations for failure to disclose
payments to an agent and for submission of forged
documents:

ble for the acts of its employees and explicitly rejected the
rogue employee defense, observing that the respondent
firm failed to show that it had effectively implemented
existing controls in place at the time of the misconduct.
In light of these findings, the Sanctions Board declined to
consider arguments based on the acts of the consultant.
The Sanctions Board found the respondent firm liable for
all misrepresentations, and the respondent individual liable
for the failure to disclose the payment to the consultant.
Sanctioning analysis: In its sanctioning analysis, the Sanctions Board applied aggravation for the severity of the

DECISION NO. 137. In this decision, the Sanctions Board

respondent firm’s conduct (repetition, management’s role).

imposed sanctions of debarment with conditional release on

The Sanctions Board applied varying levels of mitigation

a company and its managing director, with minimum periods

for the respondent’s various corrective measures (internal

of ineligibility of three years for the former and one year and

action against responsible individuals, effective compliance

six months for the latter. The respondent firm was part of a

program), cooperation (assistance and/or ongoing coop-

joint venture that submitted six bids and won two contracts

eration, internal investigation, voluntary restraint), and the

under the Electricity Modernization Project in Kenya.

passage of time since the misconduct. The Sanctions Board

Allegations, evidence, and findings: INT alleged that, in
connection with the joint venture’s bids, the respondents
failed to disclose commissions to a consultant and submitted forged documents relating to the respondent firm’s
finances and experience. The respondents admitted to
these misrepresentations but claimed no intent to mislead.

declined to grant any mitigating credit for asserted factors
that were not supported by the record (minor role), were
redundant with other mitigating factors (cessation of misconduct, voluntary disclosure), or were not related to the
respondents’ culpability or responsibility for the sanctionable practices at issue (project completion).

THE WBG SANCTIONS BOARD

« 49

50 » SANCTIONS SYSTEM ANNUAL REPORT • FISCAL YEAR 2022

Annexes
FISCAL YEAR 2022 SANCTIONS SYSTEM DATA

A. Investigations Overview
EXTERNAL INVESTIGATION CASES BY ALLEGATION, FY18–FY22

Active at End of FY22
%
Opened in FY22
%
Completed in FY22
%
Opened in FY21
%
Completed in FY21
%
Opened in FY20
%
Completed in FY20
%
Opened in FY19
%
Completed in FY19
%
Opened in FY18
%
Completed in FY18
%

FRAUD

CORRUPTION

COLLUSION

COERCION

OBSTRUCTION

TOTAL

77%

54%

41%

85%

40%

33%

70%

47%

30%

63%

58%

40%

75%

32%

14%

82%

35%

24%

70%

26%

19%

14%

71%

35%

33%

83%

34%

28%

13%

75%

28%

21%

87%

41%

30%

Note: Because cases may include more than one type of allegation (e.g., fraud and collusion), the counts by allegation type typically add up to more
than the number of cases in the Total column.

ANNEXES: FISCAL YEAR 2022 SANCTIONS SYSTEM DATA

« 51

INTERNAL INVESTIGATION CASES, FY22
STAFF

VENDOR

TOTAL

Carried over from FY21

Opened

Total

Closed
Substantiated
Unsubstantiated
Unfounded

21
1
18
2

7
3
2
2

28
4
20
4

Ending caseload

Notes: Substantiated case: A determination that based on the results
of the investigation, the evidence supports a finding of misconduct.
Unfounded case: The results of a preliminary inquiry or investigation
established sufficient evidence supporting a conclusion that misconduct,
as alleged, did not occur. Unsubstantiated case: The preliminary inquiry
or investigation, due to a lack of evidence, did not establish a reasonable
basis to warrant further investigation or a reasonable belief to substantiate that misconduct was committed. Some credible information may
have been present, which if corroborated would have established a reasonable belief, but as it stands does not rise above the suspicion level. In
other words, there was insufficient evidence to warrant an investigation
or to prove or disprove that misconduct was committed, and the decision
then falls in favor of the staff member or corporate vendor.

OVERVIEW OF INTERNAL INVESTIGATION OUTCOMES,
FY18–FY22
FY18

FY19

FY20

FY21

FY22

Cases
Substantiated
Unsubstantiated
Unfounded
Referred
Other

11
15
3
0
1

10
8
5
5
1

7
17
10
14
0

8
24
3
3
0

4
20
4
0
0

Closed

Complaints
Referred (Not
Investigated)

Notes: Referred case: A determination that the case involved issues
more suitably addressed by other venues within the WBG (e.g., EBC, HR,
SPADR). Complaints Referred (Not Investigated): Complaints involving issues not within INT’s investigative mandate were referred to other
appropriate venues within the WBG for intervention.

52 » SANCTIONS SYSTEM ANNUAL REPORT • FISCAL YEAR 2022

B. Sanctions System and Results
SANCTIONS CASES, FY18–FY22
FY18

FY19

FY20

FY21

FY22

5 YEAR TOTAL

Sanctions Cases Submitted to SDO/EO by INT

126

SDO/EO Initial Review Completed

127

Sanctions Cases Issued by SDO/EO to Respondents

120

SETTLEMENT AGREEMENTS, FY18–FY22
FY18

FY19

FY20

FY21

FY22

5 YEAR TOTAL

Settlement Agreements Submitted to SDO/EO by INT

23*

15**

SDO/EO Review Completed

27*

15**

SANCTIONS RESULTS, FY18–FY22
FY18

FY19

FY20

FY21

FY22

5 YEAR TOTAL

Firms and Individuals Temporarily Suspended

155

Sanctions Imposed Pursuant to SDO Determinations

102

Sanctions Imposed Pursuant to SB Decisions

Sanctions Imposed Pursuant to Settlement Agreements

39*

18**

120

Notes:
*In FY18, the IFC EO reviewed one settlement agreement entered into between the WBG and three respondents relating to multiple IFC Projects.
**In FY22, the IFC EO reviewed three settlement agreements entered into between the WBG and three respondents.

SANCTIONS IMPOSED, FY18–FY22

Type of Sanctions Imposed by the SDO, the WBG Sanctions Board, and Pursuant to Settlement
(Total of 274 Sanctions Imposed) (FY18–FY22)
100.0%

97.1%

90.0%
80.0%
70.0%

67.3%
61.5%

Percent

60.0%
50.0%
40.0%
30.0%

27.3%

20.0%
10.0%
2.9%
0.0%
SDO
102 Sanctions total
Fixed-Term Debarment
Debarment with Conditional
Release
Conditional Non-Debarment

5.5%

7.7%

11.1%

7.7%

11.1%

0.9%
WBG Sanctions Board
55 Sanctions total

Settlement*
117 Sanctions total

Letter of Reprimand
Debarment with Conditional Release + Conditional Non-Debarment
Fixed-Term Debarment + Conditional Non-Debarment

Note: * Includes one settlement agreement that the World Bank entered into with three respondents in FY18, and three settlement agreements
that the World Bank entered into with three respondents in FY22, in connection with IFC operations.
ANNEXES: FISCAL YEAR 2022 SANCTIONS SYSTEM DATA

« 53

LENGTH AND TYPE OF DEBARMENTS IMPOSED BY THE SDO*

(Total of 102 Debarments) (FY18–FY22)
7–8 years

6–7 years

5–6 years

4–5 years

3–4 years

2–3 years

1–2 years

0–1 year

3 1

Fixed-term Debarments

Debarments with Conditional Release

LENGTH AND TYPE OF DEBARMENTS IMPOSED BY THE WBG SANCTIONS BOARD, FY18-FY22*

(Total of 52 Debarments; Excludes 3 Non-Debarment Sanctions)
8+ years

7–8 years

6–7 years

5–6 years

4–5 years

7
2

3–4 years

2–3 years

1–2 years

0–1 year

5
Fixed-term Debarments

Debarments with Conditional Release

LENGTH AND TYPE OF DEBARMENTS IMPOSED VIA SETTLEMENT, FY18-FY22*

(Total of 100 Debarments; Excludes 14 Non-Debarment Sanctions)
7 + years

6–7 years

5–6 years

4–5 years

3–4 years
2–3 years

5
26

1–2 years

0–1 year

10
Fixed-term Debarments

Debarments with Conditional Release

Note: *Debarments for a period of exactly X years are in the higher category (e.g., a 3-year debarment is in the category “3–4 years”).

54 » SANCTIONS SYSTEM ANNUAL REPORT • FISCAL YEAR 2022

C. Lists of Firms/Individuals Sanctioned, Debarred, or Recognized by Cross-Debarment
FIRMS/INDIVIDUALS DEBARRED IN FY22
*This table does not include any affiliates controlled by the firms/individuals debarred.
**All debarments in the table below are imposed with conditional release, unless marked with “**” at the end of the length of debarment.
***CND = Conditional non-debarment, which means a firm/individual is eligible to participate in WBG operations. CND converts to debarment with
conditional release if the firm/individual does not meet the sanctions conditions.
SANCTIONED
PURSUANT TO

FIRM/INDIVIDUAL NAME

COUNTRY OF
RESPONDENT

PROJECT
COUNTRY

GROUNDS FOR
DEBARMENT

LENGTH OF
DEBARMENT

SDO Uncontested
Determination

Technique Import Export Joint
Stock Company

Vietnam

Collusion

5 years

Settlement
Agreement

Newstech Vietnam Trading and
Investment Construction Joint
Stock Company

Vietnam

Fraud

2 years, 6 months

Settlement
Agreement

Mr. Salihu Shehu Ahmad Tijani

Nigeria

Corruption

3 years, 2 months

Settlement
Agreement

Africa Development
Professional Group Ltd.

Kenya

Somalia

Fraud

1 year, 9 months

Sanctions Board
Decision

TPF Getinsa Euroestudios S.L.

Spain

Vietnam

Fraud and
Obstruction

6 years

Sanctions Board
Decision

Getinsa Ingeniería Vietnam
Co. Ltd.

Vietnam

Fraud

6 years

Sanctions Board
Decision

Thai Son Traffic Work
Construction JSC

Vietnam

Fraud and
Obstruction

6 years, 6 months

Settlement
Agreement

Ramky Enviro Engineers
Limited

India

Fraud

1 year, 8 months

Settlement
Agreement

Mr. M. Goutham Reddy

India

Fraud

1 year, 8 months

SDO Uncontested
Determination

“KogonNefteGazEnergoService” LLC

Uzbekistan

Fraud

3 years

SDO Uncontested
Determination

JV “KogonRemStroyKomplekt”

Uzbekistan

Fraud

2 years, 10 months

SDO Uncontested
Determination

PT. Tirta Wijaya Karya

Indonesia

Fraud (in
the form of
collusion)

1 year, 7 months

SDO Uncontested
Determination

PT. Karuniaguna Intisemesta

Indonesia

Fraud (in
the form of
collusion)

2 years

SDO Uncontested
Determination

Alyans Beton Limited Liability
Company

Azerbaijan

Uzbekistan

Fraud

6 years

SDO Uncontested
Determination

Mr. Ramil Bahadir Oĝlu Aliyev

Azerbaijan

Uzbekistan

Fraud

5 years

Sanctions Board
Decision

Mr. Herbert Untersteiner

Austria

Romania

Corruption
and Fraud

2 years

Settlement
Agreement*

Colas Madagascar S.A.

Madagascar

Collusion and
Fraud

2 years

Settlement
Agreement*

ADP International S.A.

France

Madagascar

Collusion and
Fraud

1 year**then CND
for 1 year

Settlement
Agreement

AIM Consultants Limited

Nigeria

Corruption

2 years, 10 months

Settlement
Agreement

Engr. Amin Moussalli

Nigeria

Corruption

2 years, 10
months**then CND
for 1 year, 6 months
continued

ANNEXES: FISCAL YEAR 2022 SANCTIONS SYSTEM DATA

« 55

FIRMS/INDIVIDUALS DEBARRED IN FY22, continued
SANCTIONED
PURSUANT TO

FIRM/INDIVIDUAL NAME

COUNTRY OF
RESPONDENT

PROJECT
COUNTRY

GROUNDS FOR
DEBARMENT

LENGTH OF
DEBARMENT

Settlement
Agreement

SoftTech IT Solutions and
Services Ltd.

Nigeria

Corruption

4 years, 2 months

Settlement
Agreement

Mr. Isah Salihu Kantigi

Nigeria

Corruption

5 years

SDO Uncontested
Determination

Dena Rahsaz Construction Co.
CJSC

Iran

Kazakhstan

Fraud

3 years, 4 months

Settlement
Agreement

Mr. Diclah Taureka

Papua New
Guinea

Collusion and
Fraud

3 years

Settlement
Agreement

Voith Hydro GmbH & Co. KG

Germany

Congo,
Dem. Rep.;
Pakistan

Collusion

1 year, 3
months**then CND
for 6 months

Settlement
Agreement

Voith Hydro Shanghai Ltd.

China

Pakistan

Collusion and
Corruption

2 years, 10
months**then CND
for 6 months

SDO Uncontested
Determination

“Supper Fortuna” LLC

Uzbekistan

Fraud

2 years, 5 months

SDO Uncontested
Determination

Links Allen SARL

Congo, Dem.
Rep.

Congo, Dem. Fraud
Rep.

3 years, 9 months

Settlement
Agreement

Centre for Training and
Consultancy

Georgia

Fraud

1 year, 6 months

SDO Uncontested
Determination

NiemTin Company Limited

Vietnam

Fraud

2 years, 10 months

Sanctions Board
Decision

Lukenya Greens Limited

Kenya

Fraud

3 years

Sanctions Board
Decision

Mr. Martin Kuria Kibaara

Kenya

Fraud

1 year, 6 months

OTHER SANCTIONS IMPOSED IN FY22
*This table does not include any affiliates controlled by the firms/individuals debarred.
**CND = Conditional non-debarment, which means a firm/individual is eligible to participate in WBG operations. CND converts to debarment with conditional release if the firm/individual does not meet the sanctions conditions.
SANCTIONED
PURSUANT TO

FIRM/ INDIVIDUAL NAME

COUNTRY OF
RESPONDENT

PROJECT
COUNTRY

GROUNDS FOR
SANCTION

SANCTION
IMPOSED

Settlement
Agreement

Bouygues Bâtiment
International

France

Madagascar

Collusion

CND for 1 year

Settlement
Agreement

Tetra Tech International
Development B.V.

Netherlands

Somalia

Fraud

CND for 1 year,
3 months

Settlement
Agreement

Voith Hydro Holding GmbH
& Co. KG

Germany

Pakistan

Failure to supervise
controlled affiliates

CND for 1 year,
9 months

56 » SANCTIONS SYSTEM ANNUAL REPORT • FISCAL YEAR 2022

CROSS-DEBARMENTS RECOGNIZED BY THE WORLD BANK GROUP IN FY22

*Controlled affiliates may be included in the firms/individuals listed below.
FIRM/INDIVIDUAL NAME

COUNTRY

GROUNDS FOR DEBARMENT

LENGTH OF DEBARMENT

Tuan Hung Ltd.

Mr. Luu Duc Tuan

Vietnam

Cross Debarment: ADB

5 years

Vietnam

Cross Debarment: ADB

5 years

Aqua RIL S.A.C.

Peru

Cross Debarment: IDB

3 years

Pedro Alejandro Egusquiza Melendez

Peru

Cross Debarment: IDB

3 years

Sargittarius Nigeria Limited

Nigeria

Cross Debarment: AfDB

2 years, 6 months

Sargittarius Henan Water Conservancy
Engineering Ltd

Nigeria

Cross Debarment: AfDB

2 years, 6 months

Empresa Constructora Gami S.R.L.

Bolivia

Cross Debarment: IDB

3 years

Félix Espinoza Martínez

Bolivia

Cross Debarment: IDB

3 years

Gonzalo Darwin Espinoza Guerrero

Bolivia

Cross Debarment: IDB

3 years

Marvin Deheri Espinoza Guerrero

Bolivia

Cross Debarment: IDB

3 years

lvanof Said Espinoza Guerrero

Bolivia

Cross Debarment: IDB

3 years

Noah Rosenkrantz

Canada

Cross Debarment: IDB

8 years

Christopher Thibedeau

United States

Cross Debarment: IDB

4 years

TTEK Inc.

Barbados

Cross Debarment: IDB

4 years

Sino-Kenya Engineering Group
Company Limited

Kenya

Cross Debarment: AfDB

3 years

Mr. Yuehua Bai

Kenya

Cross Debarment: AfDB

3 years

Asesores Bypsa

Venezuela

Cross Debarment: IDB

10 years

BFG Consulting Limited

British Virgin Islands

Cross Debarment: IDB

10 years

Digimax Services Limited

Hong Kong SAR, China

Cross Debarment: IDB

10 years

Orange Capital Limited

Hong Kong SAR, China

Cross Debarment: IDB

10 years

Ademhan Makine Tarim Insaat Gida
Nakliyat Ithalat Ihracaat Sanayi Ve
Ticaret Limited Sirketi

Türkiye

Cross Debarment: ADB

3 years, 6 months

Mr. Abdulhamit Ademhan

Türkiye

Cross Debarment: ADB

3 years, 6 months

Mr. Agus Bastoni

Indonesia

Cross Debarment: ADB

Indefinite

Mediredes S.A.S. o Gestión y Proyectos
Construcciones Group S.A.S.

Colombia

Cross Debarment: IDB

14 years

Harry Villalobos Tejada

Colombia

Cross Debarment: IDB

14 years

Omar Enrique Álvarez Escorcia

Colombia

Cross Debarment: IDB

9 years

Christiam Andrés Navarro Guarín

Colombia

Cross Debarment: IDB

3 years

Profinco Ltda.

Colombia

Cross Debarment: IDB

3 years

Armando Gómez Monsalve

Colombia

Cross Debarment: IDB

3 years

Ingenieros Consultores y Asesores
Técnicos Sociedad de
Responsabilidad Limitada de Capital
Variable

Honduras

Cross Debarment: IDB

12 years

Walterio Romero Valladares

Honduras

Cross Debarment: IDB

12 years

Tractebel Engineering S.A.

Belgium

Cross Debarment: IDB

3 years, 10 months

Sami Kunkar Kafatti

Honduras

Cross Debarment: IDB

3 years

Constructora Santa Helena S.A.
(Kundera)

Honduras

Cross Debarment: IDB

3 years

Allan Fabricio Fiallos Williams

Honduras

Cross Debarment: IDB

3 years

Proyecto de Ingeniería Centro
Americana S. de R.L.

Honduras

Cross Debarment: IDB

3 years
continued

ANNEXES: FISCAL YEAR 2022 SANCTIONS SYSTEM DATA

« 57

CROSS-DEBARMENTS RECOGNIZED BY THE WORLD BANK GROUP IN FY22, continued
FIRM/INDIVIDUAL NAME

COUNTRY

GROUNDS FOR DEBARMENT

LENGTH OF DEBARMENT

Elsa Marina Rodríguez Teruel

Honduras

Cross Debarment: IDB

3 years

Enorey International Brasil Consultoria
Ltda. (Quanam Brazil)

Brazil

Cross Debarment: IDB

3 years

Fabricio Silveira Alvez

Brazil

Cross Debarment: IDB

3 years

Sacha Breckenfeld Reck

Brazil

Cross Debarment: IDB

8 years

Weihai Construction Group Co., Ltd.

China

Cross Debarment: AfDB

2 years, 11 months

Freddy Conrado Osorio Zepeda

Honduras

Cross Debarment: IDB

3 years

Mactebac Contractors Limited

Kenya

Cross Debarment: AfDB

3 years

Mr. Joram Opala Otieno

Kenya

Cross Debarment: AfDB

3 years

Express Automation Limited

Kenya

Cross Debarment: AfDB

3 years

Mr. Robert Kamau Wachira

Kenya

Cross Debarment: AfDB

1 year, 6 months

Rockey Africa Limited

Kenya

Cross Debarment: AfDB

2 years

China CAMC Engineering Co., Ltd.

China

Cross Debarment: ADB

5 years

CP Power East Africa Limited

Kenya

Cross Debarment: ADB

2 years

Mr. Dawit Wondwossen

Kenya

Cross Debarment: ADB

2 years

CP Power East Africa Limited

Kenya

Cross Debarment: AfDB

4 years

Mr. Dawit Wondwossen

Kenya

Cross Debarment: AfDB

4 years

Pau Llopart Vidal

Spain

Cross Debarment: IDB

10 years

Javier Olcina Feliú

Spain

Cross Debarment: IDB

9 years

Pro-Immobles S.L.

Spain

Cross Debarment: IDB

10 years

Ulife América Central S.A.

Panama

Cross Debarment: IDB

8 years

Bienes Raíces y Construcciones
Nostrot S.A.

Panama

Cross Debarment: IDB

9 years

Logitrans Logística Engenharia e
Transportes Ltda.

Brazil

Cross Debarment: IDB

6 years

Antonio Carlos Marchezetti

Brazil

Cross Debarment: IDB

6 years

Mr. Mohan Krishnan Poduval

Malaysia

Cross Debarment: ADB

Indefinite

Construtora COESA S.A.

Brazil

Cross Debarment: IDB

3 years

Liberty Construction Limited

Uganda

Cross Debarment: AfDB

3 years

Mr. Edmund Mabiro

Uganda

Cross Debarment: AfDB

3 years

Mr. Ben David Etcheverry Ergueta

Bolivia

Cross Debarment: IDB

6 years

Mr. KimChhean Yim

Cambodia

Cross Debarment: ADB

Indefinite

Project Consult Institute PCI Co., Ltd.

Cambodia

Cross Debarment: ADB

Indefinite

Pyramid E&C Co. Ltd.

Cambodia

Cross Debarment: ADB

Indefinite

Branch of Canada Construction
Cooperation Limited

Cambodia

Cross Debarment: ADB

Indefinite

Branch of Royal Road Limited

Cambodia

Cross Debarment: ADB

Indefinite

Asian Technical Assistance Co., Ltd.

Cambodia

Cross Debarment: ADB

Indefinite

M.N. Mallick & Company

Bangladesh

Cross Debarment: ADB

4 years

Mr. Mahabub Alam Mallick

Bangladesh

Cross Debarment: ADB

4 years

VENDORS DECLARED INELIGIBLE IN FY2213

VENDOR NAME

COUNTRY

GROUNDS FOR INELIGIBILITY

Comsis IT Solutions Services

Afghanistan

Engaged in fraudulent and collusive practices
to improperly secure business from the Bank

58 » SANCTIONS SYSTEM ANNUAL REPORT • FISCAL YEAR 2022

LENGTH OF INELIGIBILITY

5 years

D. Referrals Overview
REFERRALS MADE IN FY22
DATE OF REFERRAL

REFERRAL RECIPIENT

NATURE OF MISCONDUCT

PROJECT

Aug-21-2021

Bangladesh

Fraud & Corruption

Chittagong Water Supply Improvement
and Sanitation Project

Dec-15-2021

French Ministry of Economy

Fraud & Corruption

Hanoi Urban Transport Development
Project

Dec-15-2021

French Ministry of Economy

Fraud, Corruption &
Collusion

Río Bogotá Environmental Recuperation
and Flood Control Project

Dec-16-2021

French Ministry of Justice

Fraud, Corruption &
Collusion

Río Bogotá Environmental Recuperation
and Flood Control Project

Dec-16-2021

French Ministry of Justice

Fraud & Corruption

Hanoi Urban Transport Development
Project

E. Integrity Compliance Overview
Note: In instances where different entities within a corporate family have been separately sanctioned, the Integrity Compliance Officer treats such entities as a single entity for portfolio counting purposes, including with respect to engagements, notifications, releases (except where different entities
within a corporate family are released at different times per their respective sanctions), etc.

INTEGRITY COMPLIANCE DATA, FY21–FY22
FY21

FY22

400

406

Entities actively engaged with the ICO (as at the end of the fiscal year)

Notifications to newly sanctioned entities

Interim Notifications to sanctioned entities

—

Entities whose sanctions were continued

Entities released from sanction

Entities sanctioned with conditional release (as at the end of the fiscal year)

Entities whose sanctions were converted

Debarment with conditional release to conditional non-debarment

Conditional non-debarment to debarment with conditional release

FIRMS AND INDIVIDUALS RELEASED FROM WBG SANCTIONS UPON SATISFACTION OF
COMPLIANCE CONDITIONS, BY SOURCE OF ORIGINAL SANCTION, FY18–FY22

15%
Sanctioned by OSD
Sanctioned by Sanctions Board

19%

Sanctioned via Settlement

66%

ANNEXES: FISCAL YEAR 2022 SANCTIONS SYSTEM DATA

« 59

FIRMS/INDIVIDUALS RELEASED FROM WBG SANCTION UPON SATISFACTION OF COMPLIANCE CONDITIONS, FY22
* Affiliates of released firms/individuals
SANCTIONED
PURSUANT TO

FIRM/INDIVIDUAL NAME

COUNTRY

DATE OF
RELEASE

SDO determination

Fujian Lugang (Group) Corporation Ltd.

China

8-Jul-21

Settlement

SAI Consulting Engineering Limited (Systra)

India

9-Jul-21

Sanctions Board Decision

Joca Ingeniería y Construcciones, S.A.

Spain

14-Jul-21

Settlement

Golden Maritime Technology

Bangladesh

16-Aug-21

Settlement

Jalal Ali Hussein Hatim Alhudiqi

Yemen, Rep.

20-Aug-21

Settlement

Rowad Al-Yemen for Contracting Architectural and Construction

Yemen, Rep.

20-Aug-21

Settlement

China Railway First Group Co. Ltd.

China

17-Sep-21

Settlement

Ms. Josephine Namaganda

Uganda

18-Nov-21

Sanctions Board Decision

Quick Projects Limited

Nigeria

22-Nov-21

Sanctions Board Decision

Mr. Elie Abou Ghazaleh

Nigeria

2-Dec-21

Sanctions Board Decision

Mr. Fadi Abou Ghazaleh

Nigeria

2-Dec-21

Sanctions Board Decision

Abou Ghazaleh Contracting Nigeria Ltd.

Nigeria

2-Dec-21

Settlement

Ingeniería Especializada Obra Civil e Industrial S.A.U.
(formerly Acciona Ingeniería S.A.)

Spain

10-Jan-22

Settlement

CNO S.A. (formerly Constructora Noberto Odebrecht S.A.)*

Brazil

28-Jan-22

Settlement

China Railway Construction Corporation Limited China Railway
Construction Corporation (International) Limited
China Railway 23rd Bureau Group

China

4-Mar-22

Settlement

Kalpataru Power Transmission Ltd

India

8-Mar-22

Sanctions Board Decision

Aktor Technical Société Anonyme

Greece

15-Mar-22

Settlement

Ferrostaal Oil & Gas GmbH

Germany

23-Mar-22

Settlement

China National Electric Engineering Co., Ltd.

China

27-Apr-22

Settlement

China Electric Design and Research Institute Co., Ltd.

China

27-Apr-22

Sanctions Board Decision

Angelique International Limited

India

18-Jun-22

Settlement

Mr. Francisco Ayala**

Ecuador

30-Jun-22

Notes:
* Several related entities remain cross-debarred via a sanction imposed by the Inter-American Development Bank.
** Two affiliates of Mr. Ayala (Ayala Consulting Cia Ltda. and Soproen Corp.) separately remain on the WBG List of Non-Responsible

60 » SANCTIONS SYSTEM ANNUAL REPORT • FISCAL YEAR 2022

Endnotes

1. In this report, the term World Bank Group (WBG) refers collectively to the International Bank for Reconstruction
and Development (IBRD); the International Development Association (IDA); the International Finance Corporation (IFC); and the Multilateral Investment Guarantee Agency (MIGA). The term World Bank (or the Bank) refers
only to IBRD and IDA.
2. For further details on the WBG’s approach to controlling corruption, please see Anticorruption Initiatives—Reaffirming Commitment to a Development Priority (http://documents.worldbank.org/curated/
en/365421591933442799/Anticorruption-Initiatives-Reaffirming-Commitment-to-a-Development-Priority).
3. To date since the two-tier system’s implementation in 2007, the IFC EO has reviewed three sanctions cases and
four settlements; all remaining cases have been resolved by the SDO.
4. The specific standards for substantiation can differ depending on the type of investigation involved. The WBG
bears the burden of proof in staff misconduct cases and must meet the requisite standard.
5. The specific standards for substantiation can differ depending on the type of investigation involved. For corporate vendor investigations, INT needs sufficient evidence to determine that it is more likely than not that the
sanctionable conduct has occurred.
6. Staff Rule 8.02: Protections and Procedures for Reporting Misconduct (Whistleblowing) “applies to reports [by
WBG staff] of suspected misconduct that may threaten the operations or governance of the Bank Group… [and
sets out] protections that apply whether the subject of the allegations is a staff member or any other person or
entity inside or outside the Bank Group.”
7. In instances where different entities within a corporate family have been separately sanctioned, the Integrity
Compliance Officer treats such entities as a single entity for portfolio counting purposes, including with respect
to engagements, notifications, releases (except where different entities within a corporate family are released at
different times per their respective sanctions), etc.
8. CNO and certain of its affiliates remain cross-debarred, however, pursuant to a separate settlement agreement
between Novonor and the Inter-American Development Bank.
9. Details can be viewed at OEC’s integrity website: https://www.oec-eng.com/en/who-we-are/integrity.
10. The standard and burden of proof in sanctions cases are described in the relevant Sanctions Procedures, all
available at: https://www.worldbank.org/en/about/unit/sanctions-system/sanctions-board#3
11. In each contested case, the Sanctions Board considers the respondent’s period of temporary suspension in
determining any sanction.
12. As determined by the WBG.
13. One of the vendor cases that INT substantiated in FY22 was off-ramped, and the non-responsibility determination is non-public, and the vendor’s name will not be included on the WBG’s public list of ineligible vendors. INT
and SPADR, with approval by the MDCAO, developed an off-ramped procedure based on a multi-factor analysis,
considering, inter alia, severity of the offense and future risk to the WBG. In these cases, INT and the WBG’s
Director of SPADR can decide that a full investigation is not warranted, based on credible and corroborated preliminary inquiry findings by INT. If the vendor is thus excluded for a specific period from receiving future contract
awards from the WBG, the ineligibility determination is not made public in SPADR’s listing of Non-Responsible
Vendors.
14. In FY22, the ICO began to send Interim Notices to non-engaged sanctioned entities approximately half-way
through their respective sanction period.

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