Take it seriously and respond within any stated deadline. Read the request carefully to understand whether it is an audit, an inspection, a request for documents or an interview invitation, and which contract it concerns. Preserve all relevant records immediately, including emails, tender files, payment records and messaging apps. Identify who in the firm was involved and avoid internal discussions that could look like coordinating accounts. Do not destroy, delete or alter documents, as obstruction is itself sanctionable. Take legal advice before submitting documents or attending interviews, so that cooperation is complete and accurate without creating unnecessary risk.

The major institutions sanction five main practices: fraud, such as false statements about experience or misrepresenting costs; corruption, such as offering or paying bribes to officials; collusion, such as bid rigging between competitors; coercion, such as threats to influence a process; and obstruction, such as destroying evidence or misleading investigators. Definitions vary slightly between institutions and appear in their procurement and anticorruption guidelines. Firms are often sanctioned for misstatements in bid documents, such as inflated experience or forged certificates, even where no bribe was involved. Liability can extend to affiliates and to firms that controlled others' conduct.

Yes, in many cases. Under the Agreement for Mutual Enforcement of Debarment Decisions, debarments of more than one year imposed by one participating institution are generally recognised by the others, which include the World Bank Group, the ADB, the African Development Bank, the EBRD and the Inter-American Development Bank. Institutions outside that agreement may have their own policies. Debarment may also affect a firm's affiliates. Development bank sanctions can therefore have regional and global effects. We assess cross-debarment risk early, because it can influence whether a firm contests a case or seeks a negotiated resolution that reduces the period.

It depends on the evidence, the strength of available defences, the likely sanction if the case is lost and the firm's commercial priorities. Contesting can be appropriate where the evidence is weak or the facts have been misunderstood, but it takes time and the sanction may be higher if the case fails. A negotiated resolution may reduce the period, allow conditional non-debarment or provide more certainty, but it usually involves accepting certain facts, which may be relevant to other authorities. We give a frank assessment of the options, including their consequences in Bangladesh and abroad, before any commitment is made.

Generally, no. Multilateral development banks are international organisations that typically enjoy immunities, and their sanctions decisions are made under their own internal procedures, which provide the main avenue for contesting a case. Bangladeshi courts are unlikely to review the merits of a sanctions decision. However, domestic consequences, such as a procuring entity's decision to terminate a contract or bar a firm under local procurement rules, may be open to challenge under Bangladeshi law. We separate the institutional process from domestic remedies and advise on each, so that efforts are focused where they can make a real difference.

Not automatically. Development bank sanctions are administrative and do not determine criminal liability. However, institutions may refer findings to national authorities, and the same facts may interest the Anti-Corruption Commission or police in Bangladesh, or prosecutors abroad, particularly in bribery cases. Individuals may also be sanctioned or named. Information provided to the institution may later be shared. We coordinate the response to the institution with advice on criminal exposure for the firm and individuals, so that the strategy in one forum does not damage the position in another, and so that individuals receive separate advice where needed.

Institutions publish guidelines on the elements they expect, such as leadership commitment, a written code, risk assessment, due diligence on agents and partners, controls on gifts, hospitality and payments, training, confidential reporting channels, investigations and discipline, and periodic review. The programme must be implemented, not just written, and supported by records. For a Bangladeshi firm, it should reflect local tender practices, use of agents and intermediaries, and family ownership structures. We design proportionate programmes, help train management and staff and prepare the evidence of implementation that a compliance office will expect before release from development bank sanctions.

It depends on the institution's rules, the type of sanction and the terms of each contract. Sanctions usually prevent new awards of financed contracts, while the treatment of existing contracts varies and may involve the borrower and the institution deciding whether work should continue. Subcontracting arrangements and joint venture roles may also be affected. We review each contract and the applicable sanctions procedures, advise on communications with the employer and procuring entity, and help plan carefully for continued performance, assignment or orderly exit, minimising disputes with clients and partners while development bank sanctions are in effect.