Sanctions, MDB Investigations & Compliance

In the global construction and energy sectors, compliance is no longer just a local regulatory requirement—it is a prerequisite for project participation.


A single sanction can close the door to international project financing across the MDB ecosystem, with knock-on effects for joint-venture partners, lenders, insurers, and procurement eligibility well beyond the originating institution.


We provide specialized counsel to contractors, consultants, and developers navigating the stringent integrity frameworks of Multilateral Development Banks (MDBs), including

 - the World Bank,

 - the European Bank for Reconstruction and Development (EBRD),

 - the Asian Development Bank (ADB) and

 - the European Investment Bank (EIB).


How We Help

Our work in this area spans the full lifecycle of integrity and sanctions risk — from prevention, through investigation, to resolution and reinstatement.


Prevention and Compliance

  • Designing and implementing Integrity Compliance Programmes aligned with the World Bank Integrity Compliance Guidelines and equivalent MDB standards
  • Pre-bid and pre-contract integrity due diligence on partners, agents, subcontractors, and acquisition targets
  • Training for management and project teams on prohibited practices (fraud, corruption, collusion, coercion, and obstruction) as defined under MDB frameworks
  • Internal policies, third-party intermediary controls, and whistleblowing procedures


Investigations and Enforcement Proceedings

  • Conducting and supervising internal investigations triggered by audit findings, whistleblower reports, or MDB inquiries
  • Representing clients before MDB integrity functions, including the World Bank's Integrity Vice Presidency (INT) and the EBRD Office of the Chief Compliance Officer (OCCO)
  • Responding to Show Cause Letters, Notices of Sanctions Proceedings, and Audit Notification Letters
  • Negotiating Settlement Agreements and Negotiated Resolution Agreements, including the structuring of compliance conditions and monitorships