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What could be worse than a several-hundred-million dollar Foreign Corrupt Practices Act fine hitting your company? How about not being allowed to even compete for many of your most important contracts for a period of several years. While most international companies are by now keenly aware of anti-corruption laws like the FCPA and the UK Bribery Act, there is generally less awareness of the enforcement regimes the World Bank Group and other multilateral development banks (MDBs) have developed to combat the improper use of the funds they lend. With more than 1,000 entities and individuals currently debarred by the bank alone, the MDBs have increasingly become investigative and enforcement heavyweights, capable of imposing crippling sanctions like multiyear debarments. Every company participating in MDB-financed projects must be cognizant of their compliance guidelines and the impact of their investigative and disciplinary functions.

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