1. LAW, JUSTICE AND DEVELOPMENT WEEK 2011 INNOVATION AND EMPOWERMENT FOR DEVELOPMENT November 14-17, 2011 Washington DC LJD LAW JUSTICE and DEVELOPMEN T

2. World Bank Sanctions 2 Law, Justice and Development Week 2011: Development of New Legal Norms and Rules to Combat Corruption through Imposition of Sanctions Washington, DC November 15, 2011

3. Why Fighting Corruption Matters We help ensure that development funds from the World Bank Group are used for their intended purposes, with economy and efficiency. 3

4. Why Fighting Corruption Matters 4 New baby-warmer Does not fit the specifications of the procurement User risks electric shock Procurement unit accepted the delivery Contract paid in full

5. The Sanctions Process INT: Investigations OES: Temporary Suspension & Adjudication (if no appeal) SANCTIONS BOARD: Adjudication (if appeal) INT /ICO: Compliance 5

6. Sanctionable Conduct; Range of Sanctions What are the sanctionable offenses at the World Bank?  Fraud  Corruption  Collusion  Coercion  Obstructive practices What sanctions can the World Bank impose?  Letter of reprimand  Conditional non-debarment  Debarment with conditional release  Restitution Baseline Sanction as of September 2010: Debarment with Conditional Release Debarred parties now will be required to meet certain rehabilitation conditions before they can apply for reinstatement to participate in WBG-financed activities 6

7. The Conditional Release Process 7 EO or Sanctions Board Issue Decision Notify of Condition & Release Process Evaluate Program & Provide Guidance Monitor Program Implemen- tation Release Decision: WBG Eligible or Application Rejected; may appeal to Sanctions Board Office of the Integrity Compliance Officer