Welcome to the homepage of the ÐÓ°ÉÂÛ̳ Office of Suspension and Debarment (OSD).
??????????????OSD, led by the ÐÓ°ÉÂÛ̳'s Chief Suspension and Debarment Officer (SDO), provides the first level of adjudication in the ÐÓ°ÉÂÛ̳'s suspension and debarment, or "sanctions," system.
ÐÓ°ÉÂÛ̳¡¯s Office of Suspension and Debarment (OSD), led by the Chief Suspension and Debarment Officer (SDO), provides the first level of adjudication in the ÐÓ°ÉÂÛ̳¡¯s suspension and debarment, or ¡°sanctions,¡± system. Since its creation in 2007, two-thirds of ÐÓ°ÉÂÛ̳ sanctions cases have been resolved on the basis of the determinations and recommendations made by OSD. The remaining cases have been decided on appeal by the ÐÓ°ÉÂÛ̳ Group Sanctions Board.
OSD is a critical component in ensuring an efficient, effective and fair sanctions process. It is the ÐÓ°ÉÂÛ̳ unit that is charged with reviewing, prior to the issuance of any sanctions case, the sufficiency of the evidence against the firms and individuals that have been accused of fraud and corruption on ÐÓ°ÉÂÛ̳-financed projects.
Sanctions cases are selected and prepared by the ÐÓ°ÉÂÛ̳¡¯s Integrity Vice Presidency (INT) on the basis of INT investigations. If INT believes that it has gathered sufficient evidence to show that a firm or individual (referred to in the sanctions system as a ¡°Respondent¡±) has engaged in sanctionable misconduct, it submits a sanctions case to OSD for review. This initial adjudication by OSD allows for the early disposition of cases without the necessity of full sanctions proceedings in every case. OSD also plays an important role in protecting the ÐÓ°ÉÂÛ̳ by imposing temporary suspensions on Respondents once OSD has determined that they have more likely than not engaged in sanctionable misconduct.
For more information about OSD and its work, please refer to the OSD Report (2nd Edition), which can be found in the "Office of Suspension and Debarment Reports" section under the "Knowledge" tab.
For the policies and procedures governing the operation of the sanctions system, please see the "Procedures" tab.
Sanctions Procedures
Bank Procedure: Sanctions Proceedings and Settlements in Bank Financed Projects (issued November 30, 2023)
This Procedure, commonly referred to as the ¡°Sanctions Procedures,¡± sets out the procedures to be followed in the administrative process by which the Bank determines whether or not to sanction parties alleged to have engaged in a sanctionable practice in connection with a Bank-financed project.
Prior versions of the Sanctions Procedures are available here:
June 28, 2016 | April 15, 2012 | January 1, 2011 (as amended July 8, 2011) | September 15, 2010 | May 11, 2009 (as amended June 25, 2010) | October 15, 2006
Other Key Documents
WBG Policy: Sanctions for Fraud and Corruption (issued June 13, 2016)
This Policy mandates an administrative system for adjudicating allegations of fraud and corruption in connection with ÐÓ°ÉÂÛ̳ Group financing or guarantee operations and imposing sanctions therefor; and identifies practices subject to sanction and possible forms of sanctions.
WBG Policy: Statute of the Sanctions Board (issued October 18, 2016)
This Policy sets out the role, composition, competence, and responsibilities of the ÐÓ°ÉÂÛ̳ Group Sanctions Board.
Prior version: September 15, 2010 | As amended February 17, 2009
Bank Directive: Sanctions for Fraud and Corruption in Bank Financed Projects (issued June 28, 2016)
This Directive sets out the institutional and normative architecture of the sanctions system; determines the jurisdiction of the sanctions system; and provides directions on the application of sanctions.
ÐÓ°ÉÂÛ̳ Group Sanctioning Guidelines (issued October 31, 2024)
This document provides guidance to those who have the discretion to impose sanctions on behalf of the ÐÓ°ÉÂÛ̳ Group as to the considerations that the ÐÓ°ÉÂÛ̳ Group believes are relevant to any sanctioning decision.
Bank Procedure: Release from Permanent Debarment Imposed on Certain Individuals (issued March 5, 2024)
This Procedure sets out a process for a termination of the sanction of ineligibility for an indefinite period of time to be awarded Bank-financed contracts imposed on individuals pursuant to sanctions procedures set out in the Operational Memorandum dated January 5, 1998, and the ÐÓ°ÉÂÛ̳ Sanctions Committee Procedures dated August 2, 2001.
Procurement Regulations and Anti-Corruption Guidelines
ÐÓ°ÉÂÛ̳ Procurement Regulations for Investment Project Financing Borrowers (for projects after July 1, 2016) -- Click here for previous versions of the Procurement Guidelines and Consultant Guidelines (for projects before July 1, 2016)
Guidelines on Preventing and Combating Fraud and Corruption in Projects Financed by IBRD Loans and IDA Credits and Grants (July 1, 2016)
Also known as "Anti-Corruption Guidelines"
Guidelines on Preventing and Combating Fraud and Corruption in Projects Financed by IBRD Loans and IDA Credits and Grants (Revised in January 2011)
Also known as "Anti-Corruption Guidelines"
User-Friendly version of the Anti-Corruption Guidelines
Brazilian Portuguese | Arabic | Spanish | Portuguese | Chinese | Russian | French
Background and Reference Documents
Sanctions System Flowchart (This visual aid is based on the Sanctions Procedures. It provides an easy-to-understand graphic explanation of the ÐÓ°ÉÂÛ̳ Group sanctions system, including the pertinent deadlines.)
Advisory Opinion on Certain Issues Arising in Connection with Recent Sanctions Cases (No. 2010/1) (November 15, 2010; released to public by the ÐÓ°ÉÂÛ̳ Legal Vice Presidency in June 2013)
ÐÓ°ÉÂÛ̳ Group¡¯s Sanctions Regime: Information Note
ÐÓ°ÉÂÛ̳ Group Sanctions Regime - An Overview (October 8, 2010)
Report Concerning the Debarment Processes of the ÐÓ°ÉÂÛ̳ - Thornburgh et al. (August 14, 2002)
Terms and Conditions of the ÐÓ°ÉÂÛ̳¡¯s Voluntary Disclosure Program - VDP (August 16, 2006)
Agreement for Mutual Enforcement of Debarment Decisions (April 9, 2010)
Office of Suspension and Debarment Reports
ÐÓ°ÉÂÛ̳ Group Issues Seventh Joint Sanctions System Annual Report
ÐÓ°ÉÂÛ̳ Group Issues Sixth Joint Sanctions System Annual Report
ÐÓ°ÉÂÛ̳ Group Issues First Joint Sanctions System Annual Report
Symposium on Supranational Responses to Corruption Knowledge Report
Global Suspension and Debarment Directory
On July 29, 2021, the Office of Suspension and Debarment (OSD) published the Global Suspension & Debarment Directory, the first ever consultative resource on exclusion systems. This Directory is the product of the 2020 Global Suspension & Debarment Survey, a global survey launched in March 2020 that captured data and information on the exclusion systems of 23 different jurisdictions and institutions. This Directory is for anyone interested in learning about how these jurisdictions employ exclusion mechanisms to prevent certain suppliers from accessing public funds.
To learn more about the Directory and check out the accompanying table, please visit the website www.worldbank.org/exclusionsurvey.
Colloquium
Fifth Suspension and Debarment Colloquium 2020
Fourth Suspension and Debarment Colloquium 2017
Third Suspension and Debarment Colloquium 2015
Publications and Articles
Fact Sheet: Two-Tier Sanctions Management Process
ÐÓ°ÉÂÛ̳ Group Sanctions System Pamphlet
The determinations of the ÐÓ°ÉÂÛ̳ Suspension and Debarment Officer posted below have been published in accordance with sub-paragraph 10.01(b) of Section III.A of the , which provides as follows:
(b) Publication of Sanctions Board Decisions and SDO Determinations. The full text of the decisions of the Sanctions Board, as well as the determinations of the SDO in uncontested proceedings, shall be publicly disclosed.
Determinations in uncontested proceedings governed by versions of the ÐÓ°ÉÂÛ̳ Sanctions Procedures adopted prior to January 1, 2011 are not publicly available. For further information on the sanctions system and the ÐÓ°ÉÂÛ̳ Sanctions Procedures, please refer to the Procedures.
IBRD/IDA Suspension and Debarment Officer (SDO)
Mr. Jamieson Andrew Smith (Chief Suspension and Debarment Officer, full-time)
For non-IBRD/IDA operational cases:
Mr. Karim Suratgar (part-time basis, in addition to his regular responsibilities)
Ms. Shamali F. De Silva (part-time basis, in addition to her regular responsibilities)
Ms. Akiko Ogawa Kawata (part-time basis, in addition to her regular responsibilities)
Email: amanea@worldbank.org
Alexandra Manea is Senior Counsel (Sanctions) in OSD, where she assists the Chief Suspension and Debarment Officer with the review and disposition of sanctions cases, and advises on institutional anti-corruption policy. Previously, Alexandra worked in the Bank¡¯s Legal Vice Presidency on governance projects in the extractive industries, with a focus on enhancing transparency and mainstreaming anti-corruption provisions in the mining legal frameworks across Africa. Before joining the Bank, Alexandra practised as a business attorney in Romania and as a legal consultant for Romania¡¯s National Anti-Corruption Strategy. She has authored numerous papers on anti-corruption efforts across jurisdictions and corporate liability for corruption offenses. With a strong belief that integrity education is one of the key solutions to sustainably reduce corruption, she speaks regularly on integrity and anti-corruption topics at various institutions, including the International Anti-Corruption Academy in Austria. A native of Romania, Alexandra holds a Ph.D. in International Anti-Corruption Law, completed in a joint program in Israel, Romania, and the U.S. with a Fulbright scholarship. She serves as a board member of the ÐÓ°ÉÂÛ̳ Group-International Monetary Fund Fulbright Network and as a mentor for the American Society of International Law¡¯s Women in International Law Group.
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Email : gklarson@worldbank.org
Gaukhar Larson is Senior Counsel (Sanctions) in OSD, where she works with the Chief Suspension and Debarment Officer to review sanctions cases and determine whether to suspend the contracting eligibility of respondent firms and individuals. Prior to joining OSD, Ms. Larson worked in the International Finance Corporation¡¯s Business Risk and Compliance Department on integrity, regulatory risk, tax and compliance matters. Earlier, she worked with the ÐÓ°ÉÂÛ̳¡¯s Financial Market Integrity Unit and Stolen Asset Recovery Initiative (StAR) on anti-corruption and financial disclosure matters. Before joining the ÐÓ°ÉÂÛ̳ Group in 2014, Ms. Larson worked for the United Nations Office on Drugs and Crime, the Organization for Security and Co-operation in Europe, and two international law firms. As an attorney in private practice, she investigated and litigated complex international fraud matters and advised local and international clients on regulatory and compliance matters. A native of Kazakhstan, Ms. Larson earned an LL.M. in Securities and Financial Regulation from Georgetown University Law Center, an LL.M. from The George Washington University Law School, and an LL.B. in International Law, with highest honors, from Kazakh National University.
Email: cliu14@worldbank.org
Chang Liu is Counsel (Sanctions) in the Office of Suspension and Debarment (OSD), where he assists the Chief Suspension and Debarment Officer in reviewing sanctions cases to determine whether to suspend respondents¡¯ eligibility for ÐÓ°ÉÂÛ̳-financed contracts. Before joining the ÐÓ°ÉÂÛ̳, Mr. Liu practiced at two international law firms and served as a law clerk for the Honorable John G. Koeltl of the U.S. District Court for the Southern District of New York. His private practice experience includes advising clients on white-collar defense, internal investigations, and complex cross-border commercial disputes. Mr. Liu speaks regularly on the ÐÓ°ÉÂÛ̳¡¯s Sanctions System and other integrity and anti-corruption related topics at various institutions and conferences. A native of China, he earned a B.S., with honors, in Economics and Urban Studies from Trinity College, Connecticut, and a J.D., cum laude, from Harvard Law School, where he served as Executive Editor of the Harvard International Law Journal.
Email : amontoya@worldbank.org
Adri Montoya is the Program Assistant at OSD. Ms. Montoya supports the unit with administrative duties, case management, and event planning. Prior to joining OSD, Ms. Montoya was the Assistant Director of the Donor Services department at CAF America. Earlier in her career, Ms. Montoya was an intern at the Embassy of the Plurinational State of Bolivia in Washington, D.C. As an undergraduate student, Ms. Montoya interned for Blue Ridge Legal Services in Harrisonburg, VA. A native of Bolivia, Ms. Montoya earned a B.A. in Political Science with a minor in Legal Spanish from James Madison University.
Email : ssafarova@worldbank.org
Shukrana Safarova is a Program Assistant at OSD, where she manages case adminstration, handles various administrative duties, and coordinates event planning. Ms. Safarova earned her B.A. Political Science, summa cum laude, from the University of the District of Columbia. A native of Azerbaijan, she also gained valuable experience as a legal intern at a litigation-oriented law firm during her college years.
Email : htran28@worldbank.org
Hai Anh Tran is a Legal Consultant in OSD, where she assists in the review and disposition of sanction cases. A native of Vietnam, Ms.Tran earned an LL.M. in Government Procurement and Environmental Law from The George Washington University Law School, an LL.M. in International Law, summa cum laude, from Transnational Law and Business University in South Korea, and an LL.B. in Hanoi Law University in Vietnam.
Email : ykim30@worldbank.org
Yoonhye Kim is a Legal Consultant in OSD, where she assists the staff attorneys in reviewing sanctions cases. Previously, she worked with the ÐÓ°ÉÂÛ̳'s Women, Business, and the Law project, an international law firm, and the Permanent Mission of the Republic of Korea to the United Nations Office and other International Organizations in Geneva, Switzerland. A native of the Republic of Korea, Ms. Kim received her B.A. in International Studies from Boston College and her J.D. concentration in International Business Law from The George Washington Law School. During law school, she served as an Articles Editor for the Federal Circuit Bar Journal.
Email : asilva9@worldbank.org
Prior to joining OSD, Mr. Silva has worked with law firms in Washington D.C. and New York, and a national non-profit organization. A Manhattan native, Mr. Silva graduated from Fordham University, summa cum laude, earning a B.A. in Political Science, with a double minor in Mandarin Chinese and Peace & Justice Studies. Currently, Mr. Silva is pursuing his J.D. at The George Washington Law School, where he participates in the student advisor program, serves as a Writing Fellow, and is a member of the George Washington International Law Review.
Email: afulling@worldbank.org
Alexander Fulling joined OSD as a legal intern in 2025. Prior to matriculating at The George Washington University Law School, he was a consultant to the Office of Foreign Assistance at the U.S. Department of State. At GW, he is an Associate on The George Washington Journal of Energy & Environmental Law (JEEL) and a contributor to the International Law and Policy Brief (ILPB). Mr. Fulling holds a bachelor¡¯s degree in Political Science & International Affairs from Wake Forest University and is positioned to graduate from GW with his J.D. in 2026. He is a native of the U.S. but was raised abroad in the United Kingdom and in the Russian Federation.
