World Bank Group Sanctions Board

  • The World Bank Group Sanctions Board, composed of seven (7) external judges, is an independent administrative tribunal that serves as the final decision-maker in all contested cases of sanctionable misconduct occurring in development projects financed by the World Bank Group (WBG). With the support of a dedicated Secretariat, the Sanctions Board functions as the second tier of the WBG sanctions system and issues final decisions on appeals of determinations reached at the first tier.


    Highlights





    LEADERSHIP

    Image

    J. James Spinner

    Sanctions Board Chair
    Image

    Giuliana Dunham Irving

    Executive Secretary to the Sanctions Board





    Contact Sanctions Board

    The World Bank 1818 H Street, N.W., MSN G 5‐503, Washington, D.C. 20433, U.S.A.
    Email
  • Image
    Background and Mission: The World Bank Group (WBG) Sanctions Board is an independent administrative tribunal that functions as the second and final tier of the WBG sanctions system and issues non-appealable decisions in all contested cases of sanctionable misconduct in development projects financed by the WBG. Under the Sanctions Board Statute, the Sanctions Board consists of seven (7) members all external to the World Bank Group: three (3) members appointed by the Executive Directors, who must not currently hold any appointment to the staff of the WBG and shall be familiar with procurement matters, law, dispute resolution mechanisms, or operations of development institutions; and two (2) members appointed for each of International Finance Corporation (IFC) and Multilateral Investment Guarantee Agency (MIGA) by the Executive Directors, who must not currently hold any appointment to the staff of the WBG and shall be familiar with private sector cross-border lending and equity investments (for IFC Projects) or non-commercial guarantee operations (for MIGA Projects). Mr. J. James Spinner currently chairs the Sanctions Board. Information on the Sanctions Board's membership is available here.

    Process: The Sanctions Board carries out a full de novo review in each contested case. It is not bound by the Suspension and Debarment Officer's or Evaluations Officers' recommendation. An administrative hearing may be held by the Sanctions Board either upon a party's request or at the discretion of the Sanctions Board Chair. In its deliberations, the Sanctions Board considers INT's allegations and evidence as attached to the Notice of Sanctions Proceedings; the respondent's arguments and evidence submitted in response to INT's allegations and evidence; INT's reply brief; the parties' presentations at a hearing, if applicable; and any other materials contained in the record. After completing its review, the Sanctions Board determines whether it is "more likely than not" that the respondent engaged in a sanctionable practice. If so, the Sanctions Board imposes one or more appropriate sanctions from a range of possible sanctions including, (i) reprimand, (ii) conditional non-debarment, (iii) debarment, (iv) debarment with conditional release, and (v) restitution or remedy, which may extend to a respondent's affiliates, successors and assigns. Debarments of over one (1) year are also subject to mutual enforcement by other multilateral development banks (MDBs). Additional details and guidance on this process are available here.

    Outcomes: The decisions of the Sanctions Board are final and non-appealable. In each of its decisions, the Sanctions Board addresses all procedural issues in dispute, the respondent's liability for the alleged misconduct, the specific sanction imposed, if any, and the scope and basis of that sanction. The decisions are circulated to the parties and/or their counsel immediately upon issuance and to other stakeholders at the WBG for their information. Decisions issued beginning in 2011 are also published in full and available at here. Although decisions issued in earlier cases are not published in full, their holdings are available in the Sanctions Board's Law Digest, issued in 2011. The Sanctions Board's published case law provides a growing body of jurisprudence and resource for parties and other international organizations. Since 2001, more than 600 firms and individuals have been publicly sanctioned by the WBG (visit www.worldbank.org/debarr for the full current list of sanctioned firms and individuals).






    Contact Sanctions Board

    The World Bank 1818 H Street, N.W., MSN G 5‐503, Washington, D.C. 20433, U.S.A.
    Email
  • World Bank Group Sanctions Documents

    WBG Policy: Sanctions for Fraud and Corruption (issued June 13, 2016)

    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.

    WBG Policy: Statute of the Sanctions Board (issued October 18, 2016)

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

    Prior version: September 15, 2010 | As amended February 17, 2009

    World Bank Group Sanctioning Guidelines (issued January 1, 2011)

    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.

    Summary of Integrity Compliance Guidelines

     

    IBRD and IDA Sanctions Documents

    Bank Procedure: Sanctions Proceedings and Settlements in Bank Financed Projects (issued June 28, 2016)

    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.

    Prior versions of the Sanctions Procedures are available here: 

    April 15, 2012  |  January 1, 2011 (as amended July 8, 2011)  |  September 15, 2010  |  May 11, 2009 (as amended June 25, 2010) | October 15, 2006

    Bank Directive: Sanctions for Fraud and Corruption in Bank Financed Projects (issued June 28, 2016)

    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.

     

    IFC, MIGA, and Private Sector Sanctions Documents

    IFC Sanctions Procedures

    This Procedures sets out the administrative process to be followed in cases involving alleged sanctionable practices, such as fraudulent, corrupt, collusive, coercive and/or obstructive practices in connection with an IFC Project and operations, non-responsibility of a vendor in procurement, or arising from a violation of a material term of the World Bank Group Voluntary Disclosure Program.

    Prior version: January 1, 2007

    MIGA Sanctions Procedures

    This Procedures sets out the administrative process to be followed in cases involving alleged sanctionable practices, such as fraudulent, corrupt, collusive, coercive and/or obstructive practices in connection with projects guaranteed by MIGA and projects in which MIGA has offered technical assistance, or arising from a violation of a material term of the World Bank Group Voluntary Disclosure Program.

    Prior version: October 15, 2006

    World Bank Private Sector Procedures

    This Procedures sets out the administrative process to be followed in cases involving alleged sanctionable practices, such as fraudulent, corrupt, collusive, coercive and/or obstructive practices in connection with World Bank guarantee and carbon finance projects, or arising from a violation of a material term of the World Bank Group Voluntary Disclosure Program.

    Prior version: 2006

     

    Procurement Regulations and Anti-Corruption Guidelines

    World Bank Procurement Regulations for Investment Project Financing Borrowers (for projects after July 1, 2016) -- Click here for previous versions of the Procurement Guidelines and Consultant Guidelines (for projects before July 1, 2016)

    User-Friendly version of the Anti-Corruption Guidelines

    Brazilian Portuguese | Arabic | Spanish | Portuguese | Chinese | Russian | French

     

    Background and Reference Documents

    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)

    The World Bank Group’s Sanctions Regime: Information Note

    World Bank Group Sanctions Regime - An Overview (October 8, 2010) 

    Report Concerning the Debarment Processes of the World Bank - Thornburgh et al. (August 14, 2002)

    Terms and Conditions of the World Bank’s Voluntary Disclosure Program - VDP (August 16, 2006)

    Agreement for Mutual Enforcement of Debarment Decisions (April 9, 2010) 





    Contact Sanctions Board

    The World Bank 1818 H Street, N.W., MSN G 5‐503, Washington, D.C. 20433, U.S.A.
    Email
  • Sanctions Board Decisions

    Consistent with the World Bank Group's commitment to transparency, the Sanctions Board is a leader among Multilateral Development Banks (MDBs) as the only sanctions appeals body that publishes fully-reasoned decisions in all types of appeals that it reviews.

    Sanctions Board decisions are final and non-appealable. In each of its decisions, the Sanctions Board addresses all procedural issues in dispute, the respondents’ liability for the alleged misconduct, the specific sanction imposed, if any, and the scope and basis of that sanction. The decisions are circulated to the parties and/or their counsel immediately upon issuance and to other stakeholders at the Bank for their information. ​

    The holdings in decisions issued between 2007 and 2011 were presented in the first edition of the Sanctions Board’s Law Digest, published in December 2011. The shift to publicly-available Sanctions Board decisions in May 2012 has resulted in the development of a body of jurisprudence that offers guidance to the international community involved in anti-corruption and sanctions.

    For further information on the sanctions system, please refer to the Key Documents.


  • World Bank Group Sanctions System Annual Report

    World Bank Group Sanctions System Annual Report (FY18)

    This inaugural report is the result of efforts by the Integrity Vice Presidency (INT), the Office of Suspension and Debarment (OSD) and the Sanctions Board to prepare a joint overview of the Bank Group Sanctions System and its activities over the past year.

     

    Sanctions Board Law Digest

    Sanctions Board Law Digest (2011)

    The 2011 Law Digest summarizes for informational purposes the evolving case law of the Sanctions Board from its inception in 2007 through October 31, 2011. The Law Digest, as prepared by the Sanctions Board Secretariat and reviewed by Sanctions Board members, comprises two parts: Case Summaries and a Case Digest. The Case Summaries provide a brief synopsis of the allegations, outcome, and procedural framework for each case. The Case Digest entries illustrate the legal principles and considerations applied by the Sanctions Board based on the facts and circumstances presented in each case.

    For further reference, the full text of Sanctions Board decisions in cases initiated on or after January 1, 2011, may be found here. A current listing of all sanctioned parties may be found at www.worldbank.org/debarr.





    Contact Sanctions Board

    The World Bank 1818 H Street, N.W., MSN G 5‐503, Washington, D.C. 20433, U.S.A.
    Email
  • Image

    Mr. J. James Spinner

    Sanctions Board Chair, World Bank Group

    Mr. J. James Spinner, a U.S. and Colombian national, was appointed as the World Bank Group Sanctions Board Chair effective October 1, 2015. Mr. Spinner previously served as General Counsel of the Inter-American Development Bank (IADB) from 2000 until his retirement in 2011. In this capacity, he participated in the development of the IADB's operational, financial, and administrative policies, as well as anti-corruption strategies. During his career at the IADB from 1977 to 2011, Mr. Spinner provided legal advice on all aspects of the IADB's activities, including its lending and guarantee operations, its financial activities on global capital markets, and corporate matters. Prior to joining the IADB, he practiced law in Washington, D.C. Mr. Spinner holds a B.A. from Lehigh University in Bethlehem, Pennsylvania, and a J.D. from Georgetown University. He is a member of the Board of Trustees of Colegio Karl C. Parrish, Barranquilla, Colombia.

    Image

    Ms. Ellen Gracie Northfleet

    Sanctions Board Member, IBRD/IDA

    Ms. Ellen Gracie Northfleet, a Brazilian national, has served on the World Bank Group Sanctions Board since 2013. An attorney in private practice and arbitrator in Rio de Janeiro, Ms. Northfleet has previously held several judicial positions in Brazil, including Federal Attorney; Judge as well as Chief-Judge of the 4th Federal Court of Appeals; Justice and later Chief-Justice of the Federal Supreme Court; and Presiding Judge of the National Judicial Council. Ms. Northfleet has received some of the highest decorations and distinguished awards for her public service. Her key contributions to the reform of the Brazilian judicial system relate, among others, to the adoption of computerized models for case filing and management, the introduction of the stare decisis system in a civil law jurisdiction, and the increased use of alternative dispute resolution. Ms. Northfleet currently serves on the Legal Board of the Federation of Industries of São Paulo – FIESP and acts as Vice-President of the Arbitration Chamber of that institution. She also serves on the Board of Directors of the World Justice Project and on the Board of the International Council for Arbitration of Sports. Ms. Northfleet holds a law degree, as well as a post-graduate degree in social anthropology, from the Universidade Federal do Rio Grande do Sul. She also studied Administration of Justice at American University (Washington, D.C.) as a fellow of the Fulbright Program.

    Image

    Ms. Catherine O'Regan

    Sanctions Board Member, IBRD/IDA

    Ms. Catherine O'Regan, a national of South Africa, has served on the World Bank Group Sanctions Board since 2012. She is currently the President of the International Monetary Fund Administrative Tribunal and the inaugural Director of the Bonavero Institute of Human Rights at the University of Oxford. She served as the Chairperson of the United Nations Internal Justice Council from 2008 to 2012. Ms. O'Regan was a Judge of the Constitutional Court of South Africa from 1994 to 2009 and an ad hoc judge of the Supreme Court of Namibia from 2010 to 2016. Ms. O'Regan holds a B.A. and an LL.B from the University of Cape Town, an LL.M from the University of Sydney, and a Ph.D. from the London School of Economics and Political Science (LSE). She is an Honorary Professor at the University of Cape Town. Ms. O'Regan has been awarded numerous honorary degrees, including from the LSE and the University of South Africa.

    Image

    Mrs. Olufunke Adekoya

    Sanctions Board Member, IFC

    Mrs. Funke Adekoya, a British and Nigerian national, has served on the World Bank Group Sanctions Board since 2014. Mrs. Adekoya is a Partner at ǼLEX, one of the largest full service commercial law firms in Nigeria where she heads the Dispute Resolution practice group. She obtained a Second Upper Law degree from the then University of Ife, Ile-Ife South West Nigeria in 1974, graduating top of her class with 3 Faculty prizes to her credit. After obtaining her professional legal qualifications from the Nigerian Law School in 1975, she attended Harvard Law School, Boston, Massachusetts USA where she obtained her LLM in 1977. She was elevated to the rank of Senior Advocate of Nigeria in September 2001. She re-qualified as a Solicitor in England and Wales in July 2004 and maintains a current practising licence. As head of the 15 member dispute resolution practice group in ǼLEX, Mrs. Adekoya provides legal representation to domestic and offshore clients, and also advises foreign counsel on matters of Nigerian law. In addition to appointments as either sole or party appointed arbitrator or as chair of the panel in both international and domestic arbitration proceedings [institutional and ad hoc], she has also acted both within Nigeria and abroad either as counsel, co-counsel or Nigerian law expert in both litigation and arbitration proceedings for offshore clients; has advised investors on potential investment treaty claims and has appeared as an expert witness on Nigerian law issues in courts in Turkey, the UK, and the United States. Mrs. Adekoya is a Fellow of the Chartered Institute of Arbitrators, also a Chartered Arbitrator and a past Chairman of its Nigerian Branch. She is also a board member of the recently established Lagos Court of Arbitration as well as of the African Users Council of the LCIA [London Court of International Arbitration]. Among other listings, Mrs. Adekoya is listed on the arbitrators' panel of the Kigali International Arbitration Centre and the Energy Arbitrators List by the International Centre for Dispute Resolution. She was also a member of the IBA Task Force which prepared the IBA Guidelines on Party Representation in International Arbitration. She is also a Vice President of the ICC Court of Arbitration.

    Image

    Mr. Cavinder Bull

    Sanctions Board Member, IFC

    Mr. Cavinder Bull, a Singapore national, has served on the World Bank Group Sanctions Board since October 2018. Mr. Bull practices at Drew & Napier LLC, one of the largest firms in Singapore, where he is the Chief Executive Officer. He has an active practice in complex litigation as well as in international arbitration where he acts both as counsel and as arbitrator in commercial and investor-state arbitrations. Mr. Bull is also Vice-President of the Singapore International Arbitration Centre (SIAC) Court of Arbitration and was the Deputy Chairman of SIAC from 2010 to 2017. He is also a member of the Governing Board of ICCA, Vice-President of the Asian Pacific Regional Arbitration Group and a member of the Asian Business Law Institute’s Advisory Board. Mr. Bull graduated with First Class Honors in law from Oxford University and holds a Masters-in-Law from Harvard Law School, which he attended on a Lee Kuan Yew Scholarship. Mr. Bull is admitted to the bars of Singapore, New York, and England & Wales. The Chief Justice of Singapore appointed him Senior Counsel in 2008, one of only a handful to have been appointed before the age of 40. 

    Image

    Mr. Mark Kantor

    Sanctions Board Member, MIGA

    Mr. Mark Kantor, a U.S. national, has served on the World Bank Group Sanctions Board since July 2017. Mr. Kantor serves as an arbitrator and mediator in commercial and investment disputes. He is a qualified arbitrator and a member ofthe American Arbitration Association Commercial and International Panels, the AAA's Large Complex Case Roster, the AAAlICDR's Energy Arbitrators List, the ICC Arbitrator Database, the Chartered Institute of Arbitrators, the London Court of International Arbitration list of arbitrators, the rosters of arbitrators of the Hong Kong, Singapore and Kuala Lumpur International Arbitration Centers, the CPR Panel of Distinguished Neutrals for Banking and Finance, the CPR International Panel, and the CPR Energy Committee. Mr. Kantor is also a Chartered Arbitrator of the Chartered Institute of Arbitrators. He is the recipient of many recognitions, including the 2011 Arbitral Women Honorable Man Award and the 2013 Best Lawyers Washington, D.C. International Arbitration - Governmental "Lawyer of the Year". Before becoming an arbitrator, Mr. Kantor worked at Milbank, Tweed, Hadley & McCloy LLP, where he was a partner in the Corporate and Project Finance Groups in the Washington, DC office. During his years of practice, his principal transactional focus was in the area of domestic and international investments and financing. He has represented sponsors and financial institutions (including export credit agencies and multilaterals) in complex project financing and other infrastructure projects in the energy, power, telecommunications, and financial services-industries. Mr. Kantor teaches courses in International Business Transactions and in International Arbitration as an Adjunct Professor at the Georgetown University Law Center (Recipient, 2006 Fahy Award for Outstanding Adjunct Professor). Mr. Kantor holds a master's degree in Public Policy from the University of Michigan's Institute for Public Policy Studies, and a J.D. from the University of Michigan Law School. He is licensed to practice law in New York and Washington DC.

    Image

    Mr. Alejandro A. Escobar

    Sanctions Board Member, MIGA

    Mr. Alejandro A. Escobar, a U.S. and Chilean national, has served on the World Bank Group Sanctions Board since July 2017. Mr. Escobar is a partner in the London office of Baker Botts L.L.P., where he has worked for the last 15 years advising businesses and states in disputes arising out of investment protection treaties and within the context of PPPs. He has handled numerous claims of expropriation and abusive regulation in various industries, including power, oil & gas, telecommunications, and public concessions and procurement. Mr. Escobar also advises on other international law issues relevant to' international business, including boundary disputes. In addition, he regularly sits as an arbitrator, including presiding over an ICC tribunal in an oil & gas concession dispute governed by English law. Prior to Baker Botts, Mr. Escobar was a Senior Counsel at ICSID where he handled numerous investment treaty matters. Aside from the practice of law, he was visiting professor at University College London, where he taught International Law of Foreign Investment, a topic he continues to lecture on to academic and professional audiences. Mr. Escobar holds a Ph.D. from the University of Cambridge, a Certificate of Merit from The Hague Academy of International Law, and a Bachelor in Law from the University of Chile. He is admitted to practice law before the Supreme Court of Chile and the Supreme Court of England and Wales.​





    Contact Sanctions Board

    The World Bank 1818 H Street, N.W., MSN G 5‐503, Washington, D.C. 20433, U.S.A.
    Email
  • Image

    Giuliana Dunham Irving

    Executive Secretary

    Ms. Giuliana Dunham Irving is the current Executive Secretary to the World Bank Group Sanctions Board. She has been with the Sanctions Board Secretariat since October 2016. Ms. Dunham Irving joined the World Bank Group in 2006 as an Institutional Integrity Officer in the Institutional Integrity Department (now the Integrity Vice Presidency). From 2008 to 2012, she held the position of Senior Counsel in Legal Department’s Institutional Administration Unit. From 2012 to 2014, she served as Senior Counsel and Special Assistant to the General Counsel and Senior Vice President of the World Bank Group. From 2014 to September 2016, she held the position of Senior Counsel for Sanctions Policy in the Legal Operations Policy Unit. Ms. Dunham Irving received her Juris Doctor from New York University School of Law in 1992, and completed her undergraduate studies in economics at Columbia College of Columbia University in New York and Universita’ Commerciale Luigi Bocconi in Milan. Ms. Dunham Irving began her legal career as a litigation associate with the firm Debevoise & Plimpton in New York. Prior to joining the World Bank Group, she served as a Trial Attorney in the Fraud Section of the United States Department of Justice and as an Assistant United States Attorney in Washington, D.C.

    Image

    Eugenia A. Pyntikova

    Counsel

    Eugenia, a dual U.S. and Russian national, joined the Sanctions Board Secretariat in October 2012. Eugenia earned her law degree from Georgetown University Law Center where she served as Notes Editor of the Georgetown Immigration Law Journal and graduated with additional distinctions as a Global Law Scholar and the Law Center's Pro Bono Pledge Honoree. Concurrently with her JD curriculum, Eugenia earned a Master's degree in Public Health from Johns Hopkins University, summa cum laude, where she focused on vaccine policy and humanitarian emergencies. Prior to law school, Eugenia worked for a global bio surveillance project at Georgetown University, where she managed a team of regional analysts monitoring diverse health emergencies. She received her Master of Science degree in Science Policy from Georgetown University and an undergraduate degree from West Virginia University, both summa cum laude. Eugenia is a member of the Bar of the State of Virginia.

    Image

    Anna Lorem Reyes Ramos

    Counsel

    Anna, a Philippine national, joined the Sanctions Board Secretariat in August 2015. Prior to joining the Secretariat, she was a Dispute Settlement Lawyer at the World Trade Organization Appellate Body Secretariat and had been a law clerk for the incumbent Chief Justice of the Supreme Court of the Philippines. Anna also previously worked in litigation in a law firm in Manila. Anna received her Juris Doctor and Bachelor of Science in Economics from the University of the Philippines, and is a member of the Philippine Bar. She obtained her Master of Laws (LL.M.) in Public International Law from Queen Mary, University of London.

    Image

    Felipe Rocha dos Santos

    Counsel

    Felipe, a Brazilian national, joined the Sanctions Board Secretariat in January 2018. Prior to joining the Secretariat, he worked at the law firm Hughes Hubbard & Reed in Washington, D.C. and Paris, where his practice focused on anti-corruption matters and complex, cross-border compliance investigations. Felipe also served as Chief of Division in the Consumer Protection Bureau of Brazil’s Ministry of Justice. He holds a Bachelor of Laws degree, with highest honors, from Universidade Federal do Rio Grande do Sul (UFRGS) in Brazil, and a Master of Laws degree from Harvard Law School. Felipe is a member of the Brazilian Bar and the Bar of the State of New York.     

    Image

    Sharon C. Louis Chandran

    Legal Analyst

    Sharon, a Malaysian national, joined the Sanctions Board Secretariat in September 2013. Prior to joining the Secretariat, Sharon was an Administrative Assistant for the International Monetary Fund (IMF) Administrative Tribunal. Sharon also worked at the World Bank Office of Suspension and Debarment (OSD) (formerly known as Office of Evaluation and Suspension (OES)) as a Junior Professional Associate. Sharon received a Master of Professional Studies in Paralegal Studies, summa cum laude, from George Washington University in 2013 and was honored by an induction into the National Paralegal Honor Society (LEX) for Academic Excellence. Sharon also received a Bachelor of Science degree, magna cum laude, in Finance from George Mason University in 2007 and received the Vision Award for Academic Excellence. Sharon has lived and worked in Malaysia and the United States.

    Image

    Amanda Schneider

    Senior Program Assistant

    Amanda, a dual U.S. and Brazilian national, joined the Sanctions Board Secretariat in August 2015. Prior to joining the Secretariat, Amanda was a Program Assistant for the Western Balkans Anchor Unit and has also worked across multiple regions during her 17 years in the Bank. Amanda received a Paralegal Certificate from The Center for Legal Studies, from George Mason University.





    Contact Sanctions Board

    The World Bank 1818 H Street, N.W., MSN G 5‐503, Washington, D.C. 20433, U.S.A.
    Email