World Bank Sanctions Program: Compliance and Enforcement

Understanding the Investigations Processes and Sanctions Decisions, Structuring Compliance Programs, Avoiding Penalties and Debarment

The World Bank's Sanctions Program Suspension and Debarment Officer Joins Panel

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

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Conducted on Tuesday, April 30, 2013

Recorded event now available

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Course Materials

This CLE course will provide guidance to counsel on the World Bank’s sanctions program and its investigations process. The panel will analyze the sanctions decisions, offer insights into the program's legal principles and practice, and outline approaches for structuring compliance programs.


There is a worldwide focus on anti-corruption beyond the U.S. FCPA. In 2012, the World Bank’s sanctions program saw an increase in investigations of 247% over 2011. Understanding and complying with the World Bank’s sanctions program is now more important than ever.

The new and still developing sanctions process includes significant compliance challenges. The World Bank published the Sanction’s Board Law Digest, giving compliance practitioners guidance through a summary of the developing legal principles and practices.

Companies that fail to meet the World Bank’s anti-corruption standards face debarment from World Bank projects, as well as potential settlement penalties. Since 2010, the World Bank and several other financial institutions agreed to cross-debar companies found in violation of the standards.

Listen as our authoritative panel analyzes the World Bank’s sanctions program to explain its investigations process. The panel will also examine the sanctions decisions, provide insight into the program's legal principles and practices, and offer approaches for compliance program structure.



  1. Investigations process
  2. Sanctions decisions
    1. Theories of liability
    2. Standards of evidence
  3. Structuring a compliance program


The panel will review these and other key questions:

  • What is the prohibited activity? How does the sanctions process work?
  • How does the World Bank's investigation process work?
  • What investigative powers does the World Bank employ and how does it coordinate with national authorities?
  • What steps should counsel and companies take to monitor and manage proper compliance with the World Bank's anti-corruption standards?

Following the speaker presentations, you'll have an opportunity to get answers to your specific questions during the interactive Q&A.


Pascale H. Dubois
Pascale H. Dubois
Suspension and Debarment Officer
The World Bank

She suspends and debars firms and individuals accused of fraud and corruption in World Bank-financed projects. She has...  |  Read More

Matteson Ellis
Matteson Ellis

Special Counsel
Miller & Chevalier

Mr. Ellis has extensive experience in all areas of international anti-corruption compliance and enforcement. With a...  |  Read More

Jonathan Shapiro
Jonathan Shapiro
Integrity Compliance Officer (ICO)
World Bank Group

He provides guidance to debarred parties for adopting and implementing integrity compliance programs and related...  |  Read More

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