Sanctionable Practices

Sanctionable practices are the five defined categories of misconduct, fraud, corruption, collusion, coercion, and obstruction, that the major multilateral development banks investigate, sanction, and debar companies and individuals for committing in connection with bank-financed projects.

What are Sanctionable Practices?

The five MDB signatories to the mdb-harmonised-framework, specifically the World Bank, ADB, AfDB, EBRD, and IDB, use a common set of definitions for the five practices. Fraud-mdb-definition covers misrepresentation to obtain a benefit; corruption-mdb-definition covers improper payments or benefits; collusion-mdb-definition covers arrangements between parties to subvert competition; coercion covers threats or harm to influence procurement conduct; and obstruction covers interference with the banks' own investigations.

Any one of the five can result in debarment from that bank's financed projects. Under the cross-debarment agreement in force since 2010, a sanction by any one of the five banks is automatically enforced by all five. The debarment lists are public, so market participants can screen counterparties before forming consortia or subcontracting arrangements.

Why Sanctionable Practices matter for bidders

Understanding the five categories is not just a legal exercise. Each category has practical hotspots in ordinary procurement work: inflated CVs (fraud), agent payments (corruption), consortium price coordination (collusion), subcontractor pressure tactics (coercion), and document handling during an inquiry (obstruction). Suppliers active across multiple MDB-financed markets benefit from an integrity-compliance-programme that maps controls to each of the five categories and trains procurement staff on the specific risk patterns rather than treating compliance as a generic ethics exercise.

FAQ

Are the five sanctionable practices defined the same way by all MDBs?

Yes. The harmonised framework agreed by the five major MDBs uses identical definitions so that a practice sanctionable at one bank is automatically sanctionable at the others, which underpins the cross-debarment mechanism.

Can a company be sanctioned for more than one practice in the same case?

Yes. A single procurement misconduct episode can simultaneously involve fraud (false bid documents), corruption (payments to an evaluator), and collusion (coordinated bidding), resulting in findings on multiple practices and potentially heavier sanctions.

Where are debarment decisions published?

Each bank publishes its own debarment list publicly. The World Bank list at worldbank.org/debarr is the most comprehensive and is updated regularly. The other four banks maintain equivalent public lists.