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Harry Cassin
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An integrative approach to suspension and debarment? No, not yet

Last Tuesday, October 9th, the World Bank hosted a colloquium on “Suspension and Debarment,” featuring four panels of experts from around the world.

Perhaps in recognition of the increased use and prominence of this integrity tool, the colloquium was very well-attended with an active and attentive audience.

The panelists discussed recent developments in the suspension and debarment regimes of the U.S. federal procurement system, the European Union and multilateral development bank (MDB) procurement. In addition to highlighting the unique features of the individual systems, panelists also considered whether a harmonized, global blacklisting system could be possible in the future. 

I was a panelist on the U.S. Suspension & Debarment panel, which focused on the highly discretionary U.S. regime. The panel highlighted the system’s approach to suspension and debarment as a business decision. The panel also addressed fundamental misconceptions about the regime, such as the view of debarment as a numbers game or tool of punishment (a topic I not only addressed at the colloquium, but have discussed frequently in past blog posts, such as here and here).

Panelists discussing the European Union’s debarment regime highlighted an issue that is of particular interest to readers of this blog–mandatory debarment. Specifically, the EU regime requires the mandatory exclusion of contractors that have been convicted of bribery or corruption. Panelists also noted that there is greater uncertainty in the EU system because the debarment provisions must be implemented by the member states—a requirement which has led to a differing interpretations and applications.  

The panelists that discussed the MDB debarment system highlighted the regime’s unique features and recent developments, such as increased transparency (the World Bank began publishing Sanctions Board decisions in 2011) and cross-debarment among the MDBs (an agreement to mutually enforce each other’s debarment actions, with respect to the four harmonized sanctionable practices, i.e. corruption, fraud, coercion, and collusion).

While nearly all the panelists agreed that a harmonized system is not currently possible given the systems’ complexities and differing goals, the colloquium set the stage for further discussions among countries and MDBs. Over the next few weeks, Andrew Reichardt and I will provide an in-depth analysis of the issues addressed by each panel during the colloquium.  In the meantime, we welcome your thoughts and questions regarding this important tool.  


Jessica Tillipman is a contributing editor of the FCPA Blog. 

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