Michael DeBernardis Discusses Addition of M&A Provisions to World Bank Compliance Guidelines

Dec. 15, 2025 – Michael DeBernardis spoke to Global Investigations Review about new compliance guidelines established by the World Bank that will consider whether companies are doing due diligence ahead of mergers and acquisitions before releasing them from debarment.

According to DeBernardis, the addition of M&A provisions to the bank’s compliance guidelines, which were announced as part of a broader update to the lender’s guidelines on Dec. 9, could be significant.

He told the publication that many large companies, particularly in Asia, allow acquired foreign entities to keep existing compliance programs rather than integrating them.

“I would hope and expect that the Integrity Compliance Office would take a pragmatic view on this,” DeBernardis said.

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