The World Bank Group (WBG) announced on Wednesday, May 30, it would begin publishing for the first time decisions issued by the WBG Sanctions Board in cases of alleged fraud and corruption. The first eight decisions are available on the World Bank’s external website, which may be accessed by clicking here. The publication of the full Sanctions Board decisions greatly increases the transparency of the sanctions process.

The WBG Sanctions Board is an independent administrative tribunal with a majority of members from outside the World Bank. It serves as the final decision-maker in contested sanctions cases. More than 530 firms and individuals have been sanctioned by the WBG for fraud, corruption and collusion since the sanction system began in 1999. Most of these sanctions are debarments, in which a firm or individual is rendered ineligible, for a period of time or permanently, to participate in WBG-financed projects or operations.

The announcement was made in connection with the first-ever public conference by the WBG Sanctions Board. At the panel discussion, titled “Upholding the Rule of Law in the Fights Against Corruption and Poverty,” Mr. Leonard McCarthy, the World Bank Vice President for Integrity noted in the last four years there have been 353 external investigations resulting in 124 sanction applications, involving 170 sanctioned entities. It is anticipated that the pace of investigations and sanctions will continue to grow.

The panel reviewed recent developments and considered the ongoing challenges for the WBG’s sanction system. Of particular note was the growing frequency of cross-debarment, with the other multinational development banks recognizing WBG debarments, and vice versa, in 111 instances over just the last two years.

This publication of WBG Sanctions Board decisions, in full, adds to the compilation of Sanctions Board precedents published in December 2011 as the “Law Digest.” Future consideration could be given to publishing the WBG settlements (Negotiated Resolution Agreements) reached between the World Bank and corporate respondents. These consensual resolutions would give companies a better gauge in assessing potential WBG sanctions and, in particular, in evaluating the wisdom of entering the WBG’s Voluntary Disclosure Program. The Bank’s sanctions process has grown dramatically in recent years and appears set to continue. For further information regarding the World Bank Group sanctions system or other anticorruption matters, please contact the authors or the Arent Fox attorney with whom you work.

About the Authors

Mark S. Radke and Peter V. B. Unger are partners with Arent Fox’s White Collar and Investigations Practice. Both are based in Washington, DC. Arent Fox is currently serving as a corporate monitor pursuant to a WBG settlement.