Learn how the World Bank Group is helping countries with COVID-19 (coronavirus). Find Out

Skip to Main Navigation

Office of Suspension and Debarment

  • The World Bank’s Office of Suspension and Debarment (OSD), led by the Chief Suspension and Debarment Officer (SDO), provides the first level of adjudication in the World Bank’s suspension and debarment, or “sanctions,” system. Since its creation in 2007, two thirds of World Bank sanctions cases have been resolved on the basis of the determinations and recommendations made by OSD. The remaining cases have been decided on appeal by the World Bank Group Sanctions Board.

    OSD is a critical component in ensuring an efficient, effective and fair sanctions process. It is the World Bank unit that is charged with reviewing, prior to the issuance of any sanctions case, the sufficiency of the evidence against the firms and individuals that have been accused of fraud and corruption on World Bank-financed projects.

    Sanctions cases are selected and prepared by the World Bank’s Integrity Vice Presidency (INT) on the basis of INT investigations. If INT believes that it has gathered sufficient evidence to show that a firm or individual (referred to in the sanctions system as a “Respondent”) has engaged in sanctionable misconduct, it submits a sanctions case to OSD for review. This initial adjudication by OSD allows for the early disposition of cases without the necessity of full sanctions proceedings in every case. OSD also plays an important role in protecting the World Bank by imposing temporary suspensions on Respondents once OSD has determined that they have more likely than not engaged in sanctionable misconduct.

    For more information about OSD and its work, please refer to the OSD Report (2nd Edition), which can be found in the "Office of Suspension and Debarment Reports" section under the "Knowledge" tab.

    For the policies and procedures governing the operation of the sanctions system, please see the "Sanctions Framework Documents" section under the "Knowledge" tab.

  • News

    Seminar on Governance and Anti-Corruption Efforts: World Bank and IMF Staff Discuss Related Challenges and Opportunities with Public Officials from Six Countries

    December 4, 2017

    Events



  • SANCTIONS FRAMEWORK DOCUMENTS

    WBG Policy: Statute of the Sanctions Board

    This Policy sets out the role, composition, competence, and responsibilities of the World Bank Group Sanctions Board. 

    Bank Directive: Sanctions for Fraud and Corruption in Bank Financed Projects

    This Directive sets out the institutional and normative architecture of the sanctions system; determines the jurisdiction of the sanctions system; and provides directions on the application of sanctions.

    Bank Procedure: Sanctions Proceedings and Settlements in Bank Financed Projects

    This Procedure, commonly referred to as the “Sanctions Procedures,” sets out the procedures to be followed in the administrative process by which the Bank determines whether or not to sanction parties alleged to have engaged in a sanctionable practice in connection with a Bank-financed project.

    WBG Policy: Sanctions for Fraud and Corruption

    This Policy mandates an administrative system for adjudicating allegations of fraud and corruption in connection with World Bank Group financing or guarantee operations and imposing sanctions therefor; and identifies practices subject to sanction and possible forms of sanctions.

    World Bank Sanctioning Guidelines

    This document provides guidance to those who have the discretion to impose sanctions on behalf of the World Bank Group as to the considerations that the World Bank Group believes are relevant to any sanctioning decision.

     

    PREVIOUS FRAMEWORK DOCUMENTS

    WBG Policy: Statute of the Sanctions Board (June 2016)

    World Bank Sanctions Procedures (as adopted by the World Bank as of April 15, 2012)

    World Bank Group Sanctions Board Statute (September 2010)

     

    BACKGROUND AND REFERENCE DOCUMENTS

    World Bank Group Sanctions System Pamphlet

    Sanctions System Flowchart

    This visual aid is based on the Sanctions Procedures. It provides an easy-to-understand graphic explanation of the World Bank Group sanctions system, including the pertinent deadlines.

    The World Bank Group’s Sanctions Regime: Information Note

    Advisory Opinion on Certain Issues Arising in Connection with Recent Sanctions Cases (No. 2010/1)

    November 15, 2010; released to public by the World Bank Legal Vice Presidency in June 2013

     

    COLLOQUIUM

    Fourth Suspension and Debarment Colloquium 2017

    The Fourth Colloquium on Suspension and Debarment showcased recent developments in suspension and debarment systems worldwide, examining the various uses of suspension and debarment in the procurement and anti-corruption contexts.

    Third Suspension and Debarment Colloquium 2015

    The Third Colloquium on Suspension and Debarment showcased the broad range of first principles underlying suspension and debarment systems, covering developing trends and potential harmonization of systems worldwide.

     

    OFFICE OF SUSPENSION AND DEBARMENT REPORTS

    The World Bank Office of Suspension and Debarment: 10-Year Update on Case Data & Metrics (Addendum to the Second Edition, 2007-2017)

    10-year update on case data and metrics in OSD's Report on Functions, Data and Lessons Learned.

    The World Bank Office of Suspension and Debarment: Report on Functions, Data and Lessons Learned (Second Edition, 2007-2015)

    Second edition of OSD's Report on Functions, Data and Lessons Learned.

    The World Bank Office of Suspension and Debarment: Report on Functions, Data and Lessons Learned (2007-2013)

     

    Publication and Articles

    Fact Sheet: Two-Tier Sanctions Management Processblic

       

  • Suspension and Debarment Officer Determinations in Uncontested Proceedings

    The determinations of the World Bank Suspension and Debarment Officer posted below have been published in accordance with sub-paragraph 10.01(b) of Section III.A of the Bank Procedure: Sanctions Proceedings and Settlements in Bank Financed Projects issued by the Bank on June 28, 2016 (the "Sanctions Procedures"), which provides as follows:

    (b) Publication of Sanctions Board Decisions and SDO Determinations. The full text of the decisions of the Sanctions Board, as well as the determinations of the SDO in uncontested proceedings, shall be publicly disclosed.

    Determinations in uncontested proceedings governed by versions of the World Bank Sanctions Procedures adopted prior to January 1, 2011 are not publicly available. For further information on the sanctions system and the World Bank Sanctions Procedures, please refer to the Key and Reference Documents.


    Sanctions Case No. 561 -- Respondents Alam & Sons Government Contractor & General Order Supplier and Mr. Khuda Dad (June 5, 2018)

    Issued on June 5, 2018
  • Image

    Jamieson Andrew Smith

    Chief Suspension and Debarment Officer , OSD

    Email : jsmith@worldbank.org

    Jamieson Smith is the Chief Suspension and Debarment Officer for the World Bank. In this role, he reviews sanctions cases and determines whether to suspend the contracting eligibility of respondent firms and individuals. Mr. Smith has spoken on multilateral institutions’ approach to anti-corruption at various domestic and international conferences, including events in France, Côte d'Ivoire, Brazil, Italy, South Africa, Denmark, Singapore and the United Kingdom. Before coming to OSD in March 2010, Mr. Smith was an attorney in private practice, where he represented corporations and individuals in a wide variety of white collar criminal and regulatory matters, including alleged violations of the U.S. Foreign Corrupt Practices Act. He has conducted internal investigations in China, Egypt, Indonesia, Brazil, Croatia, Italy and Czechia, and also advised clients with respect to compliance and corporate governance issues. Mr. Smith also teaches a course on international anti-corruption efforts as an Adjunct Professor at Georgetown University Law Center. A native of Massachusetts, Mr. Smith received his A.B., cum laude, from Duke University, and his J.D., magna cum laude, from Duke University's School of Law, where he was a member of Law & Contemporary Problems. He also earned his M.A. in American Legal History from the University of Virginia.

    Image

    Collin David Swan

    Counsel , OSD

    Email : cswan@worldbank.org

    Collin Swan is Counsel (Sanctions) in OSD at the World Bank, where he assists the Chief Suspension and Debarment Officer in reviewing sanctions cases and determining whether to suspend the contracting eligibility of respondent firms and individuals.  Prior to joining the World Bank, Mr. Swan worked as a government contracts associate at Wiley Rein LLP and served as a judicial law clerk for the Honorable Jimmie V. Reyna on the U.S. Court of Appeals for the Federal Circuit. He is also an Associate Editor for the Public Contract Law Journal and has been a Professorial Lecturer in Law at the George Washington University Law School since 2014, where he teaches courses on government contracts and scholarly writing.  A native of Pennsylvania, Mr. Swan received his B.A., summa cum laude, from the George Washington University, and his J.D., with highest honors, from the George Washington University Law School.  During law school, he won both the National Contract Management Association’s writing award and the Public Contract Law Journal writing competition. His publications include works in the Journal of National Security Law and Policy, the Public Contract Law Journal, the George Washington Law Review and the Journal of Contract Management.

    Image

    Alexandra Malina Manea

    Counsel , OSD

    Email : amanea@worldbank.org

    Alexandra Manea is Counsel (Sanctions) in OSD, where she works with the Chief Suspension and Debarment Officer on the review and disposition of sanctions cases. Previously, she worked for the World Bank’s Legal Vice Presidency as a core member of the African Mining Legislation Atlas (AMLA), a project aiming to enhance the transparency of Africa’s mining sector and to mainstream anti-corruption integrity provisions in the mining legislation across the continent. Prior to joining the World Bank in 2014, Ms. Manea worked as a private sector attorney, as a consultant for the Romanian National Anti-Corruption Strategy in Education and as assistant professor of public international law. She holds a PhD in International Anti-Corruption Law, completed in a joint program at University “TM” of Bucharest in Romania, Hebrew University of Jerusalem in Israel and American University in the US with a Fulbright scholarship. Ms. Manea is a Romanian national and holds a law degree from Babes-Bolyai University in Romania and Bourgogne University in France. Ms. Manea is also a board member of the World Bank Group – International Monetary Fund Fulbright Alumni Network.

    Image

    Gaukhar Larson

    Counsel , OSD

    Email : gklarson@worldbank.org

    Gaukhar Larson is Counsel (Sanctions) in the World Bank’s Office of Suspension and Debarment (OSD), where she works with the Chief Suspension and Debarment Officer to review sanctions cases and determine whether to suspend the contracting eligibility of respondent firms and individuals. Prior to joining OSD, Ms. Larson worked at the International Finance Corporation’s Business Risk and Compliance Department on integrity, regulatory risk, tax and compliance matters. Earlier, she worked with the World Bank’s Financial Market Integrity Unit and Stolen Asset Recovery Initiative (StAR) on anti-corruption and financial disclosure matters.  Before joining the World Bank Group in 2014, Ms. Larson worked for the United Nations Office on Drugs and Crime, the Organization for Security and Co-operation in Europe and two international law firms.  As an attorney in private practice, she investigated and litigated complex international fraud matters and advised local and international clients on regulatory and compliance matters. A native of Kazakhstan, Ms. Larson earned an LL.M. in Securities and Financial Regulation from Georgetown University Law Center, an LL.M. from The George Washington University Law School and an LL.B. in International Law, with highest honors, from Kazakh National University.

    Image

    Shirin Elizabeth Ahlhauser

    Legal Consultant , OSD

    Email : sahlhauser@worldbank.org

    Shirin Ahlhauser is a Legal Consultant (Sanctions) in OSD, where she assists the counsels and the Chief Suspension and Debarment Officer in reviewing sanctions cases and determining whether to suspend the contracting eligibility of respondent firms and individuals. Prior to joining the Bank, Ms. Ahlhauser worked with the U.S. General Services Administration, the U.S. Trade Representative and Baker and Mckenzie’s Shanghai office. She graduated from the George Washington University Law School, where she co-founded the law school’s Anti-Corruption & Compliance Association.  Ms. Ahlhauser also lived in China for six years and graduated from Nanjing University with a Masters in International Law (courses taught in Mandarin Chinese). During law school in China, she participated in the Jessup International Law Moot Court competition and served as co-president of Nanjing Community Outreach, a community service organization. A native of Tennessee, Ms. Ahlhauser received her B.S., magna cum laude, from the University of Tennessee at Chattanooga in Political Science.

    Image

    Berk Guler

    Paralegal , OSD

    Email : bguler@worldbank.org

    Berk Guler is the Paralegal in OSD. In this position, Mr. Guler prepares all logistical tasks for issuing cases, conducts anti-corruption-related research, and produces reports and other statistics related to the caseload. Prior to joining OSD, Mr. Guler worked as a transfer pricing associate at PricewaterhouseCoopers LLP in McLean, Virginia. Mr. Guler is a Turkish national who grew up in Izmir before coming to the United States in 2010 to continue his studies. He is fluent in Turkish and English. Mr. Guler graduated from Georgetown University with a B.A., magna cum laude, in Economics (Honors) and Government, and a minor in Business Administration. He is a 2021 J.D. candidate from Georgetown University Law Center.

    Image

    Haiyue Xue

    Legal Assistant , OSD

    Email : hxue1@worldbank.org

    Haiyue (Stephanie) Xue is a Legal Assistant in OSD. Ms. Xue prepares all logistical tasks for issuing cases, conducts anti-corruption-related research and produces reports and other statistics related to the caseload. Prior to joining OSD, Ms. Xue worked at the Brookings Institution and the Wilson Center. Ms. Xue is a Chinese national who grew up in Shenzhen before coming to Washington, DC to continue her studies. Fluent in Chinese and English with knowledge of Japanese and Korean, she graduated from the School of Foreign Service at Georgetown University with a B.S.F.S., summa cum laude, in Regional and Comparative Studies (Honors).

    Caroline Wachtell

    Program Assistant , OSD

    Email : cwachtell@worldbank.org

    Caroline Wachtell is the Program Assistant in OSD. In this position, Ms. Wachtell performs daily tasks equivalent to an Administrative Officer and additionally conducts anti-corruption-related research for the office. Prior to joining OSD, Ms. Wachtell worked for the Council of Women World Leaders at the United Nations Foundation. Ms. Wachtell is a Danish and American national who grew up in Denmark before coming to Washington, DC to continue her studies. Fluent in Danish and English, she graduated from the College at Georgetown University with a B.A. in English and a minor in Government.