World Bank/IFI Investigations

Steptoe represents clients from around the world in investigations and sanctions proceedings involving allegations of misconduct in projects financed by International Financial Institutions (IFIs), principally the World Bank. The IFIs (also known as multilateral development banks or MDBs), such as the World Bank and the regional development banks (African, Asian, and Inter-American Development Banks, and the European Bank for Reconstruction and Development) have established standards of conduct and sanctions mechanisms for contractors and consultants who engage in specified types of misconduct – especially fraud or corruption – on projects wholly or partly financed by these institutions.

The most common sanction has been debarment – a loss of eligibility to participate in projects financed by these institutions, often coupled with conditions for reinstatement. Sanctions are typically made public and other institutions may suspend or debar a company based on a World Bank or other MDB sanction, sometimes automatically. The impact of a sanction can therefore be quite severe.

Steptoe has extensive experience with the sanctioning regimes of the World Bank and other MDBs. One of our partners previously served as head of one of the IFI investigative offices and helped design some of the sanctions procedures currently in place in these institutions. We have successfully represented firms from around the world going back to the earliest days of the sanctions system, in audits, investigations, settlements, Show Cause letter responses, sanctions proceedings, post-sanction remediation efforts, and collateral proceedings and issues. We have also represented clients before national authorities to whom the MDBs have made a referral.

How We Can Help

• Conduct internal investigations of possible misconduct on IFI-financed projects.
• Represent consultants and contractors in audits and investigations being conducted by the World Bank’s Integrity Vice-Presidency (INT) and other IFIs as well as regional authorities such as the EU’s European Anti-Fraud Office (OLAF).
• Represent respondents in sanctions proceedings, including hearings before the World Bank’s Sanctions Board and other similar bodies.
• Represent IFI senior management personnel in investigations involving ethical codes of conduct.
• Assist with voluntary disclosure issues, including the World Bank’s Voluntary Disclosure Program (VDP)
• Assist with negotiated resolution agreements and other settlements.
• Assist with the resolution of integrity issues involving project financing by IFC and other private-sector arms of IFIs.
• Deal with World Bank and other IFI referrals to national authorities, including issues of information-sharing among authorities and representation in concurrent World Bank and national investigations and proceedings
• Advise on mitigating risks of cross-debarment under the Cross-Debarment Agreement and other collateral consequences.
• Advise on the privileges and immunities of the IFIs.
• Post-sanction representation and assistance, including representation before the World Bank’s Integrity Compliance Office (ICO).