Sanctions Officer
Sanction Code


Project Name
Support for Haiti Transportation Sector Program (Grant Agreements 2663/GR-HA, 2794/GR-HA and 3085/GR-HA)
Prohibited Practice(s)
Fraudulent Practice
Type of Sanction


Prohibited Practice(s) Text

Fraudulent Practice: The Individual Respondent was found to have engaged in a fraudulent practice by knowingly misrepresenting workforce payments to misappropriate funds, in connection with a contract for the supervision of road rehabilitation works.


The Individual Respondent (“Respondent”) was the legal representative and Chief Executive Officer of a firm subcontracted by a company awarded a contract to supervise road rehabilitation works in connection to Haiti Transportation Sector Program (the “Program”). The Office of Institutional Integrity (“OII”) submitted a Statement of Charges and Evidence against the Respondent, among others, for allegedly engaging in a fraudulent practice. OII’s specific accusations were that the Respondent engaged in a fraudulent practice by misrepresenting workforce payments and instead putting in place an opaque payment scheme that concealed the misuse of funds. Consequently, and in accordance with the Sanctions Procedures, the Sanctions Officer (“SO”) issued a Notice of Administrative Action (“Notice”) to the Respondent. The Respondent did not submit a Response.

The SO determined that it is more likely than not that the Respondent engaged in a fraudulent practice. As a result, the SO imposed a sanction of debarment for a period of seven (7) years, during which time the Respondent will be ineligible to participate or be awarded contracts for projects or activities financed by the Bank Group. In determining the sanction, the SO took into account the following aggravating factors: the sophisticated means utilized that imitated money laundering tactics designed to conceal the ultimate beneficiaries; the magnitude of losses caused by the misconduct; the Respondent’s managerial position from which he directed the implementation of the fraudulent practice; and the Respondent’s lack of cooperation. In accordance with the Sanctions Procedures, the sanction imposed entered into force immediately and the Bank provided notice of this declaration of ineligibility to the other Multilateral Development Banks that are a party to the Agreement for Mutual Enforcement of Debarment Decisions.