2 minute read | September.25.2025
Over the summer, Multilateral Development Banks (MDB) announced a series of debarments, further demonstrating the importance of robust compliance procedures among MDB fund recipients.
On July 8, 2025, the World Bank Group (the Bank) announced the 18-month debarment of GenKey Solutions B.V., a Dutch biometrics company, in connection with “fraudulent practices” under the Bank’s procurement guidelines. This sanction relates to the Bank’s approximately $10 million Liberia Social Safety Nets Project, a poverty-reduction initiative launched in 2017 to support the country’s most vulnerable households. The Bank’s investigation found that GenKey failed to disclose commissions paid or to be paid to an agent in connection with a project contract — a violation attributed to weak internal controls and supervision.
The Bank imposed GenKey’s debarment as part of a settlement agreement, under which the company acknowledged “responsibility for the underlying sanctionable practice” and committed to adopting corrective measures, including the implementation of a robust integrity compliance program. The Bank noted that the debarment period was reduced to 18-months in recognition of GenKey’s cooperation during the investigation, its acceptance of responsibility, a pre-existing compliance program and a commitment not to seek new Bank-financed contracts during the debarment period. To be released from debarment, GenKey must develop and enforce integrity measures that align with the World Bank Group Integrity Compliance Guidelines and continue to provide full cooperation with the Bank’s Integrity Vice Presidency.
GenKey’s debarment qualifies for cross-debarment under the Agreement for Mutual Enforcement of Debarment Decisions, making the company ineligible for projects financed by other major MDBs, including the African Development Bank. GenKey’s subsidiary, GenKey Africa Ltd., was also debarred by the Bank and the African Development Bank for the same period.
A few weeks later, on July 29, 2025, the World Bank Group issued a Notice of Uncontested Sanctions Proceedings confirming the debarment of Thi Son Company Limited, a Vietnamese timber trading company, for a minimum period of one year. Thi Son was found to have engaged in an obstructive practice by refusing to provide the Bank with requested documents “with an intent to materially impede” the exercise of the Bank’s inspection and audit rights. This debarment relates to the World Bank’s approximately $50 million Viet Nam Medium Cities Development Project, which was designed to improve urban infrastructure and living conditions in the Ha Nam, Lao Cai, and Vinh provinces in Vietnam. According to the Bank, Thi Son did not contest the accusations or the recommended sanction, and the debarment has now entered into force. Thi Son, and its affiliates, are ineligible to participate in World Bank Group-financed contracts or loans during the debarment period, unless and until it meets the conditions for release.
These recent actions highlight the increasing scrutiny on contractors and suppliers in donor-funded projects worldwide and underscore the importance of transparency, accountability and cooperation with MDB integrity offices.
If you are engaged in MDB projects, have become involved in an MDB investigation and/or sanctions and debarment process, or would like to discuss compliance with MDB requirements, Orrick’s team is well-equipped to assist. Please email William George and David Shipton.