“Temporary” Suspension Can Lead to Permanent Problems

Since the establishment of the Uniform Framework for Preventing and Combating Fraud and Corruption, the world’s largest multilateral development banks (MDBs), such as the World Bank Group, have increasingly sought to harmonize their investigation and sanctions procedures. This cooperation has led to, among other things, common definitions of key sanctionable practices and general sanctioning guidelines. However, MDBs have failed to adopt a unified approach to the critical issue of temporary suspension. This guest article by Hogan Lovells attorneys Peter Spivack and Malak Hamwi examines the approaches to temporary suspension of five MDBs that have many common elements but diverge on significant points. They argue that the development of a common approach to temporary suspension would increase the fairness of MDB-led investigations and enforcement proceedings. See “Spotlight on the African Development Bank Group’s Sanctions System” (Feb. 3, 2021).

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