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Compliance

Plain-language definitions of every Compliance term that shows up in government tender work.


ComplianceAML

Anti-Money Laundering (AML)

A set of laws, regulations, and procedures designed to prevent criminals from disguising illegally obtained funds as legitimate income, with direct implications for suppliers registered with international procurement bodies.

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Compliance

Beneficial Ownership Disclosure

The requirement to identify and disclose the natural persons who ultimately own or control a company bidding on an MDB-financed project or registering as a vendor with a major procurement body.

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Compliance

Coercion (MDB Definition)

In MDB procurement, coercion means impairing or harming, or threatening to impair or harm, directly or indirectly, any party or the property of any party to influence improperly a party's actions in a bank-financed project.

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Compliance

Collusion (MDB Definition)

In MDB procurement, collusion means an arrangement between two or more parties designed to achieve an improper purpose, including influencing improperly the actions of another party in a bank-financed project.

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Compliance

Corruption (MDB Definition)

In MDB procurement, corruption means directly or indirectly offering, giving, receiving, or soliciting anything of value to improperly influence the actions of another party in a bank-financed project.

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ComplianceCTF

Counter-Terrorism Financing (CTF)

The set of legal and regulatory obligations requiring buyers, banks, and suppliers to prevent funds or assets from being used to finance terrorist organisations, with direct relevance to international procurement compliance.

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Compliance

Cross-Debarment

The agreement among the five major multilateral development banks under which a sanction imposed by one bank is automatically enforced by all the others.

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Compliance

Debarment

A formal sanction that bars a company or individual from competing for contracts financed by a multilateral development bank for a defined period.

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ComplianceFCPA

Foreign Corrupt Practices Act (FCPA)

A US federal law that prohibits US persons and companies, and foreign companies listed on US exchanges, from bribing foreign government officials to obtain or retain business, with broad extraterritorial reach affecting international procurement.

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Compliance

Fraud (MDB Definition)

In MDB procurement, fraud means any act or omission that intentionally misleads a party to obtain a financial or other benefit, or to avoid an obligation, in connection with a bank-financed project.

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Compliance

Independent Compliance Monitor

An external expert appointed by an MDB or enforcement authority to oversee a sanctioned company's implementation of its integrity compliance programme and report independently on whether the company is meeting its remediation commitments.

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Compliance

Integrity Compliance Programme

A structured internal system of policies, controls, training, and reporting mechanisms that a company implements to prevent, detect, and respond to fraud, corruption, and other sanctionable practices in its procurement activities.

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Compliance

Integrity Due Diligence

The process of researching a counterparty, partner, or supplier before entering a business relationship to identify sanctions, debarment, corruption history, or beneficial ownership concerns that could create compliance or reputational risk.

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ComplianceKYS

Know Your Supplier (KYS)

A due diligence process used by large buyers, particularly Gulf state-owned enterprises and MDB-funded agencies, to verify a supplier's legal status, ownership, financial standing, and integrity before awarding a vendor code or contract.

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Compliance

MDB Harmonised Framework for Preventing and Combating Fraud and Corruption

The common set of definitions, investigation procedures, and cross-debarment rules adopted by the five major multilateral development banks to detect and sanction fraud and corruption in development-financed projects worldwide.

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Compliance

MDB Harmonised Framework for Preventing and Combating Fraud and Corruption

The shared agreement among the five major multilateral development banks that aligns their definitions of sanctionable practices, investigation procedures, and cross-debarment enforcement to create a unified global standard for procurement integrity.

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Compliance

Misprocurement

A formal World Bank finding that a borrower's procurement violated the applicable regulations, triggering the Bank's refusal to finance the affected contract and requiring the borrower to repay any disbursed funds from its own resources.

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Compliance

Obstruction (MDB Definition)

In MDB procurement, obstruction means deliberately destroying, falsifying, or concealing evidence, or materially impeding an MDB's investigation into alleged sanctionable practices in a bank-financed project.

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CompliancePEP

Politically Exposed Person (PEP)

A person who holds or has recently held a prominent public function, such as a government minister or senior official, whose position creates elevated corruption risk requiring enhanced due diligence from suppliers and financial institutions.

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Compliance

Sanctionable Practices

The five categories of misconduct, fraud, corruption, collusion, coercion, and obstruction, that multilateral development banks investigate and that can result in debarment from all bank-financed projects.

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Compliance

Sanctions List (OFAC, UN, EU)

The principal international sanctions lists maintained by the US Treasury's OFAC, the UN Security Council, and the EU, which procurement bodies and suppliers must screen counterparties against before entering contracts.

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Compliance

UK Bribery Act

A UK law that prohibits offering, giving, requesting, or receiving bribes in both public and private sectors, with broad extraterritorial reach and a strict corporate liability offence for failing to prevent bribery by associated persons.

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Compliance

UN Supplier Code of Conduct

The minimum ethical, labour, environmental, and anti-corruption standards that suppliers must commit to meeting as a condition of registration with any United Nations procurement body.

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ComplianceVDP

Voluntary Disclosure Program (VDP)

A World Bank mechanism that allows companies to self-report sanctionable practices, cooperate with remediation, and implement an integrity programme in exchange for reduced or avoided debarment.

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Compliance

Whistleblower Protection

The legal and procedural safeguards that protect individuals who report suspected fraud, corruption, or other sanctionable practices in bank-financed or government procurement projects from retaliation by their employers or other parties.

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