The Office of Institutional Integrity (“OII”)  submitted a Statement of Charges and Evidence against one Individual Respondent (“Principal Respondent”) and a Respondent Firm (“Principal Respondent Firm”) for allegedly engaging in fraudulent, corrupt and collusive practices related with the Establishing Cadastral Registry and Strengthening Legal Certainty Protected Areas Program in Guatemala (the “Program”). OII identified an Individual (“Individual Respondent”) that was the legal representative of the Principal Respondent Firm and had a relationship with the Principal Respondent. According to Section 8.3 of the Sanctions Procedures, OII requested to extend the sanction imposed to the Principal Respondent and to the Principal Respondent Firm to the Individual Respondent.

The Sanctions Officer (“SO”) determined that it is more likely than not that the Principal Respondent Firm and the Principal Respondent engaged in fraudulent, corrupt, and collusive practices. As a result, the SO imposed a sanction of debarment. Further, pursuant to Section 8.3 of the Sanctions Procedures, the SO extended these sanctions to the Individual Respondent.

Subsequently, the Principal Respondent, the Principal Respondent Firm and the Individual Respondent appealed the SO’s Determinations before the Sanctions Committee (the “Committee”). In the Appeal of the Principal Respondent and the Principal Respondent Firm to the Committee, both respondents denied committing the prohibited practices, and the Individual Respondent contested the extension of the sanction.

Following a de novo review of the written record, the Committee imposed a thirteen (13) year debarment during which time the Principal Respondent and the Principal Respondent Firm will be ineligible to participate or be awarded contracts for projects or activities financed by the Bank. In accordance with Section 8.3 of the Sanctions Procedures, the Committee also extended these sanctions to the Individual Respondent. In deciding to include the Individual Respondent, the Committee took into consideration that (i) the Individual Respondent had common business interests with the Principal Respondent due to their familial relationship, and identity of interests among family members, also (ii) the Individual Respondent was the legal representative of the Principal Respondent Firm.