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The World Bank is reviewing its system for suspending and debarring contractors (known formally as the World Bank sanctions system). The system is used to suspend and debar contractors that have engaged in fraud or corruption (and other enumerated bad acts) related to Bank-financed projects. After reviewing the sanctions process, and identifying what appear to be the Bank’s current goals in its sanctions system (stemming reputational and fiduciary risks), the article recommends that the World Bank defer finalizing any reforms until it concludes its assessment of first principles, and has at hand all the data necessary to assess the sanctions system against those first principles. Reform of the World Bank sanctions system is important, both to those working on World Bank projects and to the broader developing world. The World Bank finances tens of billions of dollars in procurement every year, across the globe, and its procurement guidelines—and its sanctions system—offer important models for nations and institutions building new systems to fight corruption in procurement.

GW Paper Series

GWU Legal Studies Research Paper No. 2013-132; GWU Law School Public Law Research Paper No. 2013-132