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Multilateral Development Bank Investigations and Sanctions

Hughes Hubbard & Reed LLP • A New York Limited Liability Partnership

One Battery Park Plaza • New York, New York 10004-1482 • +1 (212) 837-6000

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“Multilateral Development Bank Investigations and Sanctions”

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Hughes Hubbard represents companies and individuals around the world in investigations and sanctions proceedings by Multilateral Development Banks (“MDBs”) such as the World Bank Group (WBG), the African Development Bank (AfDB), the Asian Development Bank (AsDB), the European Bank for Reconstruction and Development (EBRD), and the Inter-American Development Bank (IADB). MDBs are aggressive in investigating and pursuing sanctions for misconduct such as fraud, corruption, or collusion on the projects the MDB funds.  MDB sanctions can be crippling for companies working in the developing world and can have financial and reputational impacts that can go far beyond the imposed sanction.  Defending and resolving these matters requires deep knowledge of the MDB sanctions process and the strategies best suited to each matter.

Hughes Hubbard’s breadth and depth of experience and history of success in all aspects of MDB investigations and sanctions proceedings is unmatched.   We have assisted dozens of clients in the resolution of these matters, from audits, investigations, and Show Cause letter responses, to formal sanctions proceedings.  We also have deep experience with post-sanction remediation and release efforts.  We frequently serve as “buffer counsel” between clients and compliance monitors, and we have served numerous times as compliance monitors jointly appointed by MDBs and companies subject to compliance obligations. We draw on this comprehensive knowledge to guide clients through every step of the sanctions process from proactive compliance, through notice, resolution, and remediation of alleged violations.  

In addition to skilled litigators, our team includes former investigators and policy makers at multiple MDBs.  While at the WBG, one member of our team served as the first integrity compliance officer (ICO), and was a principal draftsman of the WBG's Integrity Compliance Guidelines.  Our diverse team and intimate knowledge of the unique practices and processes of each MDB allows us to tailor and execute efficient and effective strategies for our clients in these critical matters.

For further information, please contact:

Photo of 		Michael A. DeBernardis

Michael A. DeBernardis

Co-Chair

Photo of Kevin T. Abikoff

Kevin T. Abikoff

Co-Chair

MDB Investigations and Sanctions Matters

  • Represented a Chinese state-owned infrastructure company in contested proceedings before the World Bank Group Sanctions Board; secured immediate termination of suspension and proceedings. Sanctions Board Decision No. 88 (Sanctions Case No. 372) issued on June 29, 2016
  • Represented a French consulting company and individual in contested proceedings before the World Bank Group Sanctions Board; obtained acquittal on all charges by the Sanctions Board, reversing decision of the Office of Suspension and Debarment, and terminating suspension and proceedings. Sanctions Board Decision No. 81 (Sanctions Case No. 215) issued on September 29, 2015
  • Represented a Norwegian consulting engineering company in contested proceeding before the World Bank Group Sanctions Board; secured immediate termination of suspension and proceedings. Sanctions Board Decision No. 63 (Sanctions Cases No. 119 and No. 124) issued January 31, 2014
  • Represented a “Central” Chinese state-owned enterprise in connection with Negotiated Settlement Agreement with the AfDB related to allegations of fraud and collusion.  
  • Represented a French infrastructure company in connection with Negotiated Resolution Agreement with the WBG related to misconduct on a WBG-financed project in Zambia.  
  • Represented a Spanish construction company in connection with an investigation by the AfDB related to fraud and corruption.
  • Represented a Chinese state-owned infrastructure company in connection with a sanctions investigation by the AfDB involving alleged sanctionable practices related to projects in Africa.
  • Represented a Chinese design and engineering company in connection with an AsDB investigation and allegations of misconduct; secured resolution of the matter that involved no period of debarment. 
  • Represented an executive of a company cooperating with a WBG investigation for sanctionable practices; matter was resolved without charges against the executive.

Post-Sanction Release and Monitorship Experience

  • Represented a Chinese SOE subject to a conditional debarment by an MDB; assisted the company in meeting cooperation and compliance obligations under its Negotiated Settlement Agreement; coordinated with independent compliance monitor and assisted company in obtaining early release from debarment.
  • Serving as the independent compliance monitor for a Chinese state-owned construction enterprise in connection with a debarment and sanction by the WBG.
  • Represented large hydropower company subject to conditional non-debarment by an MDB; assisted the company in meeting cooperation and compliance obligations under the Negotiated Settlement Agreement; coordinated with independent compliance monitor and assisted company in obtaining early release from its conditional non-debarment.
  • Serving as the independent integrity compliance consultant jointly appointed by a Chinese company and an MDB in connection with the company’s three-year debarment.
  • Serving as an independent integrity compliance expert to assess a debarred company’s bidding controls in connection with a WBG debarment.
  • Represented French-based multinational hydropower company in enhancing its integrity compliance program and coordinating with the independent compliance monitor appointed in connection with a WBG debarment; assisted company in obtaining release from debarment and full reinstatement to eligibility.
Photo of Kevin T. Abikoff

Kevin T. Abikoff

Co-Chair

Photo of 		Michael A. DeBernardis

Michael A. DeBernardis

Co-Chair

Photo of 		Benjamin Britz

Benjamin Britz

Partner

Photo of 		Anne  Hukkelaas Gaustad

Anne Hukkelaas Gaustad

Partner

Photo of Michael H. Huneke

Michael H. Huneke

Partner

Photo of Christine Kang

Christine Kang

Partner

Photo of Laura N. Perkins

Laura N. Perkins

Partner

Photo of 		Bryan J. Sillaman

Bryan J. Sillaman

Partner

Photo of 		Jan   Dunin-Wasowicz

Jan Dunin-Wasowicz

Counsel

Photo of Tamara Kraljic

Tamara Kraljic

Counsel

Photo of Samuel Salyer

Samuel Salyer

Counsel

Photo of 		Michael R. Silverman

Michael R. Silverman

Senior Counsel

Photo of O. Ayoka Akinosi

O. Ayoka Akinosi

Associate

Photo of Jiaxing Hao

Jiaxing Hao

Associate

Photo of 		Wilson (Yifan)  Wang

Wilson (Yifan) Wang

Associate

Photo of Jonathan Zygielbaum

Jonathan Zygielbaum

Associate

Recent Recognitions for Hughes Hubbard’s Anti-Corruption and Internal Investigations Group
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Hughes Hubbard Assists Large Chinese SOE with Successful Release from World Bank Sanction | HHR团队助力中国某国有施工企业顺利获得世界银行解除制裁
News & Events
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HHR Team Represents a Chinese SOE in Obtaining a Successful Release from World Bank Sanction | HHR团队助力中国某综合性国企顺利获得世界银行解除制裁
News & Events
View News Article
HHR Team Assists Large Chinese Company with Successful Release from World Bank Sanction | HHR 团队协助中国某大型企业成功获得世界银行解除制裁
News & Events
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Firm Named to 2021 Global Investigations Review (GIR) 100
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Hughes Hubbard欢迎顶尖中国律师康乂作为合伙人加盟 推动多边开发银行调查合规以及国际仲裁业务的进一步发展
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Preeminent Chinese Practitioner Christine Kang Joins Hughes Hubbard Partnership With Practice to Focus on Investigations, Anti-Corruption, Sanctions and International Arbitration
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Download the MDB Sanctions and Investigations Primer

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HHR Team Assists Large Chinese Company with Successful Release from World Bank Sanction | HHR 团队协助中国某大型企业成功获得世界银行解除制裁 View News Article
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