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

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

A live 90-minute CLE webinar with interactive Q&A

Thursday, April 25, 2019

1:00pm-2:30pm EDT, 10:00am-11:30am PDT

Early Registration Discount Deadline, Friday, March 29, 2019

or call 1-800-926-7926

This CLE webinar 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

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Strafford will process CLE credit for one person on each recording. All formats include program handouts. To find out which recorded format will provide the best CLE option, select your state:

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