World Bank / MDB investigations and sanctions

The World Bank and other multilateral development banks (MDBs) - such as the Inter-American Development Bank, the European Investment Bank, the European Bank for Reconstruction and Development, the Asian Development Bank, and the African Development Bank – investigate, sanction and debar a growing number of companies each year for misconduct. Companies face such consequences if they engage in fraud, bribery, or corruption when participating in infrastructure or other projects financed by the World Bank or other MDBs.

MDBs maintain an elaborate investigation and adjudication process designed to evaluate allegations of misconduct. Parties deemed culpable by an MDB are listed on publicly available lists and are debarred from participating in MDB-funded projects. The various MDBs maintain a cross-debarment arrangement whereby a company blacklisted by one MDB will also be disqualified by other MDBs. In certain cases, MDB debarment can also trigger follow-up or parallel investigations by other MDBs or enforcement agencies of relevant national governments.

DLA Piper is among the world’s largest international law firms. Our legal practitioners have significant investigations, defence and litigation, and compliance experience and can advise companies facing investigation, sanctions and debarment proceedings by the World Bank and other MDBs. Our lawyers address all stages of the sanctions process, including advising on responding to initial investigations and Notice of Sanctions, supporting clients as they navigate the World Bank’s Voluntary Disclosure Program, and representing clients in appeals to the World Bank’s Sanctions Board. Experience shows that a thorough internal investigation, combined with a well-formulated defence, is essential to address any sanction action.

Our MDB practitioners regularly advise clients on the creation and implementation of robust legal and ethics compliance programmes and other remediation measures. Such efforts can play an instrumental role in addressing concerns not only of national enforcement agencies, but also of MDBs.

Our experience/expertise includes:

  • defending corporations facing regulatory or criminal investigations as well as civil claim challenges;
  • conducting multijurisdictional corporate internal investigations across all business sectors in the UK, Continental Europe, the US, the Middle East and Asia;
  • providing clients with a deep understanding of the sanctions processes of the World Bank and other MDBs;
  • preserving privilege, mitigating business interruption, and providing strategic advice on how to respond to World Bank investigations, including how to improve compliance processes to prevent future challenges; and
  • rapidly responding to incidents and emergencies 24 hours a day, 365 days a year across the globe.