The World Bank and the regional development banks, including the African Development Bank (AFDB), the Asian Development Bank (ADB), the European Bank for Reconstruction and Development (EBRD), and the Inter-American Development Bank (IADB), have adopted polices and procedures to eliminate opportunities for corruption associated with their operations and to tie their lending to progress in combating corruption.
Eligibility and Debarment
An individual or entity can be found to be ineligible or debarred, either indefinitely or for a stated period of time, for engaging in corrupt or fraudulent practices in competing for, or in executing, a contract financed by a multilateral development bank. Debarment by one may also have implications for being made ineligible for procurements at other multilateral development banks as well as before government agencies in a growing number of countries.
The implementation of an adequate compliance program has the benefit of enhancing an entity’s ability to secure opportunities with the multilateral lending institutions. In this regard, DEMING PLLC works with entities to develop effective compliance programs. DEMING PLLC also works with entities to assist them in vetting their proposals to ensure that the compliance-related concerns of the multilateral lending institutions are adequately addressed.
Investigations and Hearings
The World Bank and other multilateral lending institutions now regularly investigate allegations of questionable conduct associated with projects subject to their financing. An investigation can lead to charges being made and a follow-up hearing process whereby an entity can contest the charges. DEMING PLLC represents individuals and entities that may be investigation and, in addition, the hearing process should charges be brought. Where necessary, DEMING PLLC is also well-positioned to serve as a monitor.
Voluntary Disclosure Program
The World Bank has established what it describes as a Voluntary Disclosure Program (VDP) as a means for an individual or entity to take remedial action to address conduct that might otherwise pose an impediment to securing opportunities through the World Bank or might lead to the imposition of sanctions for current projects with the World Bank. DEMING PLLC represents entities seeking to participate in the VDP process. It is prepared to direct an internal investigation as part of the VDP process.