Multilateral Development Bank Investigations and Sanctions
Strategic representation in MDB investigations and sanctions matters, leveraging deep procedural and institutional knowledge
Hughes Hubbard’s Multilateral Development Bank Investigations and Sanctions practice represents companies and individuals worldwide in investigations and sanctions proceedings conducted by multilateral development banks, including the World Bank Group, African Development Bank, Asian Development Bank, European Bank for Reconstruction and Development and Inter-American Development Bank. Multilateral Development Banks (MDBs) aggressively pursue allegations of fraud, corruption and collusion on projects they finance, and the resulting sanctions can carry severe financial, operational and reputational consequences, particularly for companies operating in developing markets. Navigating these matters effectively requires deep familiarity with MDB sanctions regimes and a strategic, institution specific approach.
Hughes Hubbard’s experience in MDB investigations and sanctions proceedings is extensive and market leading. The firm has assisted dozens of clients at every stage of the process, from audits, investigations and Show Cause responses to formal sanctions proceedings, negotiated resolutions and post sanction remediation. The team also advises on reinstatement and release efforts, frequently serves as buffer counsel between clients and compliance monitors, and has been appointed on numerous occasions as an independent compliance monitor for sanctioned entities.
Drawing on this experience and a detailed understanding of each MDB’s procedures and enforcement priorities, Hughes Hubbard develops efficient, effective strategies to guide clients from proactive compliance through resolution and remediation of alleged violations.
Our Experience
MDB Investigations and Sanctions Matters
Chinese state‑owned infrastructure company in contested proceedings before the World Bank Group Sanctions Board, securing immediate termination of suspension and proceedings. Sanctions Board Decision No. 88 (Sanctions Case No. 372), June 29, 2016.
French consulting company and an individual in contested proceedings before the World Bank Group Sanctions Board, obtaining acquittal on all charges, reversal of the Office of Suspension and Debarment’s decision, and termination of suspension and proceedings. Sanctions Board Decision No. 81 (Sanctions Case No. 215), Sept. 29, 2015.
Norwegian consulting engineering company in contested proceedings before the World Bank Group Sanctions Board, securing immediate termination of suspension and proceedings. Sanctions Board Decision No. 63 (Sanctions Cases No. 119 and No. 124), Jan. 31, 2014.
Central Chinese state‑owned enterprise in a Negotiated Settlement Agreement with the African Development Bank related to allegations of fraud and collusion.
Large Asian infrastructure company in Inter-American Development Bank investigation and contested sanctions proceeding related to an alleged fraudulent practice in connection with a project in Ecuador.
Spanish construction company in an investigation by the African Development Bank involving allegations of fraud and corruption.
Asian design and engineering company in connection with an Asian Development Bank investigation involving allegations of misconduct, securing a resolution with no period of debarment.
Asian construction company in an investigation by the European Investment Bank into potential fraud.
Post-Sanction Release and Monitorship Experience
Global Fortune 100 state‑owned enterprise subject to conditional debarment by an MDB, including advising on cooperation and compliance obligations under a Negotiated Settlement Agreement, coordinating with an independent compliance monitor, and obtaining early release from debarment.
Independent compliance monitor for a Global Fortune 50 construction company in a debarment imposed by the World Bank Group.
Large hydropower company subject to conditional non‑debarment by an MDB, including advising on compliance and cooperation obligations, coordinating with an independent compliance monitor, and securing early release from conditional non‑debarment.
Independent integrity compliance consultant jointly appointed by a mid-sized international contractor and the African Development Bank in a three‑year debarment.
Independent integrity compliance expert engaged to assess bidding controls and compliance enhancements for a large Chinese state-owned enterprise in a World Bank Group debarment.
French‑based multinational hydropower company in enhancing its integrity compliance program and coordinating with the independent compliance monitor appointed in a World Bank Group debarment, resulting in release from debarment and full reinstatement.
Latest Updates
Litigation Wrap: First Quarter 2025
Read about the firm’s most exciting recent litigation and arbitration victories in our Litigation Wrap for the first quarter of 2025.Michael DeBernardis and Jonathan Zygielbaum Co-Author Chapter for Global Investigations Review’s Guide to Multilateral Development Bank Investigations
Michael DeBernardis and Jonathan Zygielbaum co-authored the chapter “Rules of evidence in MDB sanctions proceedings” for Global Investigations Review’s (GIR) Guide to Multilateral Development Bank Investigations.Firm Named to Global Investigations Review’s GIR 30 List for Second Year in a Row
The firm was named to Global Investigations Review’s (GIR) GIR 30 list, a ranking of the best law firms for complex multijurisdictional corporate investigations. The ranking measures firms’ institutional strengths based on a range of factors, including a firm’s reach, caseload and appearances before government authorities.Resources
This primer offers a practical overview of key Foreign Corrupt Practices Act risks and enforcement issues involving multilateral development banks.
Download the New MDB Sanctions and Investigations PrimerGIR's The Guide to Multilateral Development Bank Investigations- Second Edition: "Rules of Evidence in MBD Sanctions Proceedings"
Read the ChapterGIR's The Guide to Monitorship- Fourth Edition: "Spotlighting Multilateral Development Bank Monitorships"
Read the ChapterAll Things Investigations Podcast
The All Things Investigations podcast discusses key legal issues in white-collar and other investigations in the U.S. and abroad.
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