World Bank Group Sanctions Board

No. The Sanctions Board is an external tribunal that serves as a final decision-maker in the World Bank Group’s sanctions proceedings. It is an optional resource for all respondents who disagree with the findings or sanctions recommended by the first-tier decision-maker. If you choose to bring your case before the Sanctions Board, you will have an additional opportunity to present your defense and submit additional arguments and evidence. The Sanctions Board reviews all cases independently, impartially, and fairly, and without any deference to the first-tier’s findings and recommendations.

No. Proceedings before the Sanctions Board are administrative in nature. The Sanctions Board is not a court of law. Although there is no requirement for an attorney, you may use one. Attorney fees are not covered by the World Bank Group.

The Notice issued to a respondent sets out a timeline for submitting a Response. The Response deadline is 90 days from the date that the Notice of Sanctions Proceedings is delivered to a respondent, in some cases, this timeline may change as a result of extensions. Respondents and Named Affiliates are responsible for complying with the deadline; the World Bank Group will not send deadline notifications or reminders. If you are in doubt of the Response deadline, please contact the Sanctions Board Secretariat for a clarification in writing – sanctionsboard@worldbank.org.

For more information, please see: “Section III.B, sub-paragraph 5.1(a): Respondent's Response to Notice of Sanctions Proceedings” in the World Bank Sanctions Procedures and other parallel procedures for MIGA, IFC, and IBRD/IDA Private Sector projects as may apply in an individual case. The Sanctions System Flowchart is another helpful tool that describes the case timeline.

Yes. Requests should be made prior to the expiration of the deadline and sent to the Sanctions Board Secretariat at sanctionsboard@worldbank.org. You are asked to specify the reason for the extension request and attach any relevant evidence. The Sanctions Board Chair determines whether to grant or deny extension requests.

For more information, please see: “Section III.B, sub-paragraph 5.2(b): Extensions of Time Periods for Filing Submissions” in the World Bank Sanctions Procedures and other parallel procedures for MIGA, IFC, and IBRD/IDA Private Sector projects as may apply in an individual case.

You are not required to follow a particular format or use any specific terms in your Response. Nevertheless, at a minimum, you are advised to identify yourself as the respondent in the case, as well as any representatives who may be acting on your behalf in the proceedings (likewise for any Named Affiliate). In addition, it is generally helpful to present all arguments clearly and concisely, along with supporting documentation and other evidence where available.  For example, you may wish to state explicitly what aspects of the first-tier decision are being challenged (i.e., the findings of liability, the recommended sanction, or both). Any arguments regarding jurisdiction, redactions, or other matters, should be included in the Response, if possible.

If you are contesting liability for a sanctionable practice, it is generally helpful to consider each element of the applicable definition when structuring your Response and organizing your arguments. The relevant elements are typically outlined in the Statement of Accusations and Evidence submitted by the World Bank Group’s Integrity Vice Presidency.

If you wish to request a hearing, this request should be clearly made in the Response. Such requests should be clear and unconditional. If the request is vague or conditional (e.g., “I am available for a hearing” or “I would welcome a hearing if needed”), the Sanctions Board Chair may grant it or deny it, in their discretion.

All written materials submitted to the Sanctions Board must be submitted in English, except that exhibits (evidence) should be in the original language with the pertinent parts translated into English. The Sanctions Board Chair may require that other parts or the entirety of an exhibit be translated into English.

Please note that if you submit partial translations, the Sanctions Board will only review and consider the parts in English. 

Yes. If you have access to relevant evidence not already in the record, you should submit it together with the Response. It is always helpful to clarify the relevance of the evidence and present it in an organized format.

For more information, please see: “Section III.B, sub-paragraph 5.1(c): Submission of Additional Materials” in the World Bank Sanctions Procedures and other parallel procedures for MIGA, IFC, and IBRD/IDA Private Sector projects as may apply in an individual case.

After the Response is sent to sanctionsboard@worldbank.org, the Sanctions Board Secretariat will review the submission and:

-          Confirm receipt and acceptance of the Response, if appropriate;

-          share the Response and any accompanying evidence with INT;

-          confirm the due date for INT’s Reply; and

-          state whether the Response included a request for a hearing.

After this written confirmation, you can expect to receive INT’s Reply, typically within 30 days. If the case includes a hearing, the Sanctions Board Secretariat will follow-up with additional information regarding scheduling. In some cases, you may also receive additional information from the Sanctions Board Secretariat if the Sanctions Board wishes to invite any additional clarifications from the parties, authorize other submissions, or rule on interim procedural requests.

No. Hearings are granted to those respondents who make a timely request for a hearing in the Response, or to INT if they so request in the Reply. Outside of these submissions, the parties may still request that a hearing be held, but those requests may be granted or denied at the Sanctions Board Chair’s discretion. Importantly, in a case where neither party requests a hearing at any point, a hearing may nevertheless be called by the Sanctions Board Chair.

For more information, please see: “Section III.B, sub-paragraph 6: Hearings” in the World Bank Sanctions Procedures and other parallel procedures for MIGA, IFC, and IBRD/IDA Private Sector projects as may apply in an individual case.

Some basics on what happens during a hearing are set out in the World Bank Sanctions Procedures (“Section III.B, sub-paragraph 6: Hearings”). Before a hearing is convened, the parties receive additional information from the Sanctions Board Secretariat regarding hearing logistics and rules on participation. If you need any special accommodations for the hearing, such as simultaneous interpretation or authorization to use demonstrative materials to show during arguments, you may submit a request to the Sanctions Board Chair, via the Secretariat. As a general matter, most hearings consist of three parts: opening statements by the parties, questioning of the parties by the Sanctions Board, and closing statements by the parties.

A Sanctions Board decision can only be issued after a record in a case is closed. This means that all submissions have been received, any interim procedural motions have been addressed, and the hearing (if any) has been held. Following close of record, the Sanctions Board deliberates and drafts a decision. There is no deadline for this part of the process, which is fact-specific and depends on the complexity of the case. In the past 5 years, a decision has generally been published within 3-4 months of close of record, on average.

As an institution, the World Bank Group has internal systems and rules to protect sensitive data and documents. All evidence and arguments in a sanctions proceeding are considered “strictly confidential” under World Bank Group rules. This means that, with narrow exceptions, case information cannot be disclosed to individuals not directly involved in the same sanctions proceedings. Information about respondents’ temporary suspension pending resolution of sanctions proceedings is available to limited staff at the World Bank, without additional details on the allegations or evidence in a specific case.

Only after a sanctions case is closed and a decision is issued, information about the sanction, including identity of respondents, can be made public. In cases where no sanction is imposed and a proceeding is terminated, the respondents’ identity is not made public.

For more information, please see Section III.A, sub-paragraphs 6.3(a), 8.2(a), 10.3, and 11.5 of the World Bank Sanctions Procedures and other parallel procedures for MIGA, IFC, and IBRD/IDA Private Sector projects as may apply in an individual case.

The Sanctions Board Secretariat is available to address any questions or requests for clarification from respondents in proceedings before the Sanctions Board. We request that any questions be submitted in writing to sanctionsboard@worldbank.org.