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World Bank Sanctions Board

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Background and Mission: The World Bank (WB) Sanctions Board is an independent administrative tribunal that functions as the second and final tier of the WB sanctions system and issues non-appealable decisions in all contested cases of sanctionable misconduct in development projects financed by the WB. Under the Sanctions Board Statute, the Sanctions Board consists of seven (7) members all external to the World Bank: three (3) members appointed by the Executive Directors, who must not currently hold any appointment to the staff of the WB 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 WB and shall be familiar with private sector cross-border lending and equity investments (for IFC Projects) or non-commercial guarantee operations (for MIGA Projects). Ms. Maria Vicien Milburn 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 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 WB  (visit for the full current list of sanctioned firms and individuals).