World Bank Debarments Continued Throughout the COVID 19 Pandemic: Are There More to Come?

In the past year, the World Bank has committed its highest level of financing in a decade in response to the COVID‑19 pandemic. Financing of that magnitude inevitably carries the risk of fraud, corruption and other improper activities. In this article, Ryan Rohlfsen, Sean Seelinger, Michael Marzano and Zachary Navabi of Ropes & Gray review the World Bank’s Sanctions System, crisis response and its major enforcement actions in 2021 to date, which all indicate that, although the pandemic has led to a number of practical and administrative challenges, the World Bank’s enforcement efforts have increased and will likely continue to accelerate as more pandemic relief is distributed – and scrutinized. See “The World Bank’s Wide Reach and Its Growing Anti-Corruption Program” (May 28, 2014).

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