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Harry Cassin
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World Bank sanctions (but doesn’t debar) CDM Smith for non-compliance in Vietnam

The Boston engineering company that paid $4 million last week to settle FCPA offenses in India was also sanctioned by the World Bank Thursday for failing to disclose a subcontract on a project in Vietnam.

The World Bank “conditionally non-debarred” CDM Smith Inc. and its affiliates for one and a half years. 

“Conditional non-debarment”means CDM Smith is still eligible to participate in World Bank-financed projects as long as it meets the conditions of its negotiated resolution agreement.

The company was working on a consulting contract for the Da Nang Priority Infrastructure Investment Project in Vietnam financed by the World Bank.

During the project, CDM Smith failed to disclose a sub-consulting agreement with a local Vietnamese company, the World Bank said.

It also didn’t “seek a contractually-required written approval of the agreement.”

The sanction started June 29 and runs until December 28, 2018. It can be shortened to 15 months if CDM Smith meets its conditions for release.

The resolution agreement requires CDM Smith to adopt “a Corporate Compliance Program consistent with the World Bank Group Integrity Compliance Guidelines, and fully cooperate with the Bank in advancing its anticorruption work.”

In last week’s FCPA enforcement action, CDM Smith paid $4 million to resolve offenses in India.

The company entered into a a declination with disgorgement with the Justice Department on June 29, the same day it settled with the World Bank.

The DOJ said employees and agents of CDM Smith and a wholly owned subsidiary in India paid $1.18 million in bribes to government officials. In return, the company won highway construction supervision and design contracts and a water project contract.

The World Bank said Friday that CDM Smith fully and voluntarily disclosed the misconduct in Vietnam and cooperated with the Bank.

The World Bank’s full list of debarred and otherwise sanctioned firms and individuals is here.


Richard L. Cassin is the publisher and editor of the FCPA Blog.

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