Rahman Ravelli’s Joshua Ray wrote about the approach being taken by multilateral development banks towards companies’ compliance programmes.
The World Bank’s enforcement arm has indicated that it is now investing time and resources into assessing companies’ compliance programmes during the course of an investigation. This marks a change from its previous approach, which saw it examining company compliance only after a sanction had been imposed.
The new approach comes after US Department of Justice guidance on evaluating corporate compliance, and indicates similarities in the approaches taken by law enforcement and MDBs.
This was emphasised in Josh’s article, which was published by the FCPA Blog.