Multilateral Development Bank Investigations and Sanctions

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.