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World Bank Anti-Corruption Enforcement: What Companies and Counsel Need to Know

Engaging With the Bank, Providing Information, and Structuring Compliance Programs

Recording of a 90-minute CLE webinar with Q&A

This program is included with the Strafford CLE Pass. Click for more information.
This program is included with the Strafford All-Access Pass. Click for more information.

Conducted on Thursday, April 25, 2019

Recorded event now available

or call 1-800-926-7926

This CLE course will guide counsel on the World Bank's sanctions and investigations processes. The panel will offer insights into the program's legal principles and practice, and outline approaches for engaging with the Bank, providing information and structuring compliance programs.


The World Bank has become increasingly aggressive about enforcing the Bank's sanctionable practices, including fraud and corruption. In some ways, these enforcement actions mirror those taken by U.S. regulators under the Foreign Corrupt Practices Act. But there are significant differences too.

The Bank's jurisdiction is broader than that of the U.S. government in that it picks up parties anywhere in the world that bid on, participate in, and/or benefit from World Bank contracts. And the Bank's standard of proof for establishing a violation is less rigorous than the standard for criminal liability under the FCPA. Simply put, the Bank is afforded ample discretion when investigating and sanctioning allegations of misconduct. And sanctions can be severe.

Listen as our authoritative panel analyzes the Bank's sanctions process, from how matters are initiated to how they get adjudicated. The panel will also discuss best practices for minimizing sanctions when under review by the Bank.



  1. Bank sanctions process
    1. Jurisdiction
    2. Role of Integrity Vice Presidency (INT)
    3. The scope of sanctionable conduct
  2. Anatomy of a bank investigation
    1. Initiation of investigation and preliminary assessment
    2. Two-tiered sanctions process
      1. Evaluation by Office of Suspension and Debarment (SDO)
      2. Sanctions Board
    3. Determination of recommended action
      1. Debarment, cross-debarment and conditional release
    4. Settlement process
  3. Best practices
    1. Engagement with bank
    2. Strategy when providing information
    3. Affirmative compliance enhancements
    4. Effective advocacy


The panel will offer an exchange of views, both from the outside counsel perspective and the Bank perspective, on topics such as the following:

  • What constitutes prohibited activity under Bank rules
  • How Bank investigations start
  • How the Bank investigation process works
  • The investigative powers the Bank employs, including its coordination with national authorities
  • Steps counsel and companies should take to monitor and manage proper compliance with Bank rules
  • Recommended steps for responding to a Bank investigation


Fetzer, Lindsey
Lindsey B. Fetzer

Bass Berry & Sims

Ms. Fetzer focuses her practice on white collar and corporate compliance matters, including healthcare fraud and abuse...  |  Read More

Thaddeus R. McBride

Bass Berry & Sims

Mr. McBride represents companies and individuals in international trade regulatory, compliance, investigative, and...  |  Read More

Tiang, David
David Tiang

Founding Partner
Tiang & Partners

Mr. Tiang’s practice focuses on governance, risk management and compliance. He also has extensive experience in...  |  Read More

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