First tier : Sanctions Office

SNSO is the first instance level of the Bank Group’s Sanctions System established by the Board of Directors in July 2012. It is an independent body, mandated under the rules of the Bank Group to impose sanctions on firms and individuals for engaging in corrupt, fraudulent, collusive, coercive and obstructive practices (collectively defined as “Sanctionable Practices”) in connection with the Bank Group’s financed activities. SNSO is not competent to consider allegations of Sanctionable Practices against Bank staff.

SNSO is composed of a Sanctions Commissioner, an Alternate Sanctions Commissioner, a Sanctions Secretary and an Administrative Assistant. The Sanctions Commissioners are external experts selected for their experience in the legal field and in the fight against corruption. They are appointed by the Board of Directors, for a three-year term, renewable once.

The Office of Integrity and Anti-Corruption (PIAC) refers cases and negotiated settlement agreements to SNSO for consideration. With regard to cases, the Sanctions Commissioner renders decisions that are administrative in nature, upon review of the written submissions from PIAC and the alleged wrongdoer. The Sanctions Commissioner may impose a sanction if he/she is satisfied that there is sufficient evidence to support the allegations of Sanctionable Practices. With regard to settlement agreements concluded between the entity or the individual alleged to have engaged in the Sanctionable Practice and PIAC, the Sanctions Commissioner’s role is limited to ensuring such agreements are fair, transparent and credible. The agreements become binding after being cleared by the Sanctions Commissioner.

 The Sanctions Commissioner may impose various sanctions, the predominant one being the debarment of entities or individuals, whom as a result will be ineligible for a fixed or indefinite period, to participate in or benefit directly or indirectly from any of the Bank Group’s financed activities. Sanctions may also be imposed on executive officers and associated parties of the sanctioned firm. Sanctioned entities and individuals are included in the list of debarred entities available on the Bank Group’s website.

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