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Global Suspension & Debarment Directory

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Click here to download the Global Suspension & Debarment Directory!

We are pleased to introduce the Global Suspension & Debarment Directory, the first ever consultative resource on exclusion systems. This Directory is the product of the 2020 Global Suspension & Debarment Survey, a global survey launched in March 2020 that captured data and information on the exclusion systems of 23 different jurisdictions and institutions. This Directory for anyone interested in learning about how these jurisdictions employ exclusion mechanisms to prevent certain suppliers from accessing public funds.

Recording of Free Webinar – A Comparative Study of Exclusion Systems

On September 16, 2021, the World Bank Office of Suspension & Debarment, GW Law Government Procurement Law Program, and ABA International Anti-Corruption Committee co-hosted a free webinar on the Global Suspension & Debarment Directory.

To access the webinar’s recording, please click here.

Additional resources: 



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Collin David Swan, Senior Counsel, OSD

Email: cswan@worldbank.org

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  • This interactive table contains information on the exclusions systems of the 23 jurisdictions in the Directory.

    To learn more about each system, click on the jurisdiction name.

    JurisdictionRegionGovernment-Wide Exclusion Framework?Decision-Maker(s)Are Exclusion Decisions Made Outside Procurement Process?Effect of ExclusionOfficial List of Excluded Suppliers?Types of Excluded SuppliersDuration of Exclusions
    AustraliaAustraliaNo (ad hoc at agency level)Contracting OfficerDepends on agencyDepends on agencyNoCorporationsNo set duration
    BrazilLatin AmericaYesCentralized, Agency, JudicialYesGovernment-wideYesIndividuals & Corporations1-10 years
    CanadaNorth AmericaYesCentralizedYesGovernment-wideYes (Corporate Suppliers Only)Individuals & Corporations10 years
    ChinaEast Asia and PacificYesCentralizedYesGovernment-wideYesIndividuals & Corporations1-5 years
    Costa RicaLatin AmericaYesCentralized, Contracting OfficerDependsGovernment-wide or Agency-wideYesIndividuals & Corporations2-10 years
    El SalvadorLatin AmericaYesAgencyYesGovernment-wideYesIndividuals & Corporations1-5 years
    EstoniaEuropeYesContracting OfficerNoIndividual ProcurementNoIndividuals, Corporations, & Associations3-5 years
    GermanyEuropeYesContracting OfficerNoIndividual ProcurementNot Yet (In Process)Individuals & Corporations3-5 years
    GuatemalaLatin AmericaYesCentralized, Agency, JudicialDependsGovernment-wideYesIndividuals & Corporations1-5 years
    HondurasLatin AmericaYesContracting OfficerNoIndividual ProcurementNoIndividuals & Corporations1-5 years
    Korea, Republic ofEast Asia and PacificYesCentralized, AgencyNoGovernment-wideYes (Not Publicly Available)Corporations & their Representatives1 month - 2 years
    NetherlandsEuropeYesContracting OfficerNoIndividual ProcurementNoCorporations3-5 years
    NicaraguaLatin AmericaYesCentralizedYesGovernment-wideYesIndividuals & Corporations1-3 years
    PolandEuropeYesContracting OfficerNoIndividual ProcurementNoIndividuals & Corporations3-5 years
    Rajasthan, IndiaSouth AsiaYesCentralized, Agency, Judicial, Contracting OfficerDependsGovernment-wide or Agency-wideNoIndividuals & CorporationsUp to 3 years
    SerbiaEuropeYesAgencyNoIndividual ProcurementNoIndividuals & Corporations3-10 years
    South AfricaAfrica Eastern and SouthernYesCentralized, Judicial, Contracting OfficerDependsIndividual Procurement or Government-wideYesIndividuals & CorporationsUp to 10 years
    SwedenEuropeYesJudicial, Contracting OfficerDependsIndividual Procurement or Government-wideYes (Trading Prohibitions Only)Individuals & Corporations (Trading Prohibitions apply only to individuals)3-10 years
    United Nations High Commissioner for RefugeesInternational OrganizationYesCentralizedYesAll UN Agencies (except exclusions based on poor performance)Yes (Not Publicly Available)Corporations1 month - 5 years
    United StatesNorth AmericaYesAgencyYesGovernment-wideYesIndividuals & CorporationsUp to 3 years, longer if warranted
    World Bank Corporate ProcurementInternational OrganizationYesCentralizedYesAll WBG Vendor ContractsYesCorporations, Sole Proprietors, Independent ContractorsNo set duration (default is 3 years)
    World Bank Group Sanctions SystemInternational OrganizationYesCentralizedYesAll WBG-Financed ActivitiesYesIndividuals & CorporationsNo set duration (default is 3 years)
    WTO Agreement on Government Procurement 2012Plurilateral TreatyPermissiveGPA Party's DiscretionGPA Party's DiscretionGPA Party's DiscretionNot AddressedNot AddressedNot Addressed

    This work is a product of the staff of the World Bank.

    While believed reliable, the World Bank does not guarantee the accuracy, reliability, or completeness of the content included in this work, or for the conclusions or judgments described herein, and accepts no responsibility or liability for any omissions or errors (including, without limitation, typographical errors and technical errors) in the content whatsoever or for reliance thereon. The boundaries, colours, denominations, and other information shown on any map in this work do not imply any judgment on the part of the World Bank concerning the legal status of any territory or the endorsement or acceptance of such boundaries. The findings, interpretations, and conclusions expressed in this volume do not necessarily reflect the views of the World Bank, its Board of Executive Directors, or the governments they represent.

    This Directory contains materials drawn from many sources. The inclusion of, or reference to, any materials in this Directory does not mean that they are in any way approved, endorsed, or recommended by the World Bank. References to materials in this Directory are those that are available publicly and should not be relied on as a substitute for the original source. The Directory includes hyperlinks to electronically published documents which are not under the control of the Bank.

    This Directory is intended for information purposes only and is not intended to constitute legal advice, an interpretation, or opinion on the exclusion systems included in the Directory.

    Nothing herein shall constitute or be construed or considered to be a limitation upon or waiver of the privileges and immunities of any of the organizations of The World Bank Group organizations, all of which are specifically reserved.

    Rights and Permissions

    The material in this work is subject to copyright. Because the World Bank encourages dissemination of its knowledge, this work may be reproduced, in whole or in part, for non-commercial purposes as long as full attribution to this work is given. All queries on rights and licenses should be addressed to World Bank Publications, The World Bank, 1818 H Street NW, Washington, DC 20433, USA; e-mail: pubrights@worldbank.org.

    Cover design: © Veronica Gadea / World Bank. Further permission required for reuse.

  • Summaries of Individual Jurisdictions:

    To learn more about each system, click on the jurisdiction name to download the summary from the full Directory:

    • About the Directory:

      The Directory summarizes each jurisdiction’s exclusion regime and includes references and links (if available) to the relevant laws and regulations. Each jurisdiction’s summary presents information on six key areas relating to the exclusion system’s structure and operation:

      i. Government-Wide Legal and Institutional Framework

      ii. Functioning and Enforcement of the Government-Wide Exclusion System

      iii. Substantive Grounds for Government-Wide Exclusion

      iv. Scope and Effect of Government-Wide Exclusion

      v. Government-Wide Transparency: The Exclusion List

      vi. Limited Scope Exclusion Systems

      The idea for an exclusion survey first came about in 2015, when the World Bank Office of Suspension and Debarment (“OSD”) began to systematically study how exclusion mechanisms are used by countries and organizations globally. OSD’s research discovered a lack of commonality across jurisdictions and a significant gap in interdisciplinary research on exclusion mechanisms. Indeed, many different terms have been used to describe this remedy, such as “debarment,” “disqualification,” “suspension,” “exclusion,” or “blacklisting.” Whatever the label, the general intent of these mechanisms is to remove a wayward supplier from participating in a specific procurement process or from accessing public funds for a period of time. OSD’s efforts eventually led to the development of a survey questionnaire to gather knowledge and comparable data on exclusion systems from as many jurisdictions as possible.

      In 2018, OSD partnered with the Sanctions Officer for the Inter-American Development Bank Group (“IDB”) (comprised of the IDB, IDB Invest, and IDB Lab) and Le Bureau de l’inspecteur general de la Ville de Montréal to form a Working Group under the International Bar Association’s (“IBA”) Anti-Corruption Committee. Between May and October 2018, the Working Group launched and tested a pilot of the Global Suspension & Debarment Survey to formalize the questionnaire.

      In March 2020, the first formal round of the Survey was officially launched under the auspices of the newly formed Debarment and Exclusions Subcommittee of the IBA’s Anti-Corruption Committee. Thanks to the invaluable input from the Survey’s responders and a team of devoted researchers, this Directory marks the first dedicated taxonomy of exclusion systems and will aid future efforts to identify commonalities and differences across jurisdictions.

    • Acknowledgments of Contributors:

      We received input from numerous private practitioners, government officials, and academics with knowledge of exclusions in their jurisdictions that proved instrumental in developing this Directory. Indeed, this project would not have been possible without the knowledge, advice, and assistance of these esteemed experts:

      • Mr. Anes Kafedžić, LANDWIESER Rechtsanwälte Partnerschaft mbB
      • Mr. Carlos Ayres, Founding Partner, Maeda, Ayres e Sarubbi Advogados
      • Ms. Christine Kang, Partner, JunHe LLP
      • Professor Dae-in Kim, Ewha Womans University School of Law
      • Mr. Daniel Rodríguez, Former Associate, BLP
      • Mr. David Naus, Senior Director, Integrity Regime, Departmental Oversight Branch, Public Services and Procurement Canada
      • Mr. Duc H. Nguyen, Suspension and Debarment Official, U.S. Environmental Protection Agency
      • Mr. Federico Barrios, Director, BLP-Nicaragua
      • Dr. Florian Wolf, Counsel, Blomstein Partnerschaft von Rechtsanwälten mbB
      • Mr. Ivis Alvarado, Associate, BLP
      • Mr. Jonathan Shapiro, Owner, Shapiro Advisors LLC
      • Mr. José Álvarez, Partner, BLP
      • Mr. Juan Carlos Tristán, Partner, BLP
      • Ms. Mari Simovart, Dr. iur., Associate Professor, University of Tartu School of Law
      • Mr. Michał Kania, Professor of Law, University of Silesia
      • Ms. Mirella Lechna-Marchewka, Attorney-at-Law, Wardynski and Partners
      • Ms. Nadia Arriaga, Former Associate, BLP
      • Ms. Renata Politanski, Associate, Maeda, Ayres e Sarubbi Advogados
      • Mr. Ricardo Pagliari Levy, Partner, Pinheiro Neto Advogados
      • Mr. Robert Wyld, Consultant, Johnson Winter & Slattery
      • Mr. Rodney Grandon, Managing Director, Affiliated Monitors, Inc.
      • Mr. Roman Majtan, Procurement Specialist, The World Bank
      • Mr. Sandeep Verma, Principal Secretary to Government of Rajasthan (India)
      • Prof. Dr. Sarah Schoenmaekers, Endowed Professor of European Law, Open University; Associate Profesor of European Law, Programme Director Masters, Faculty of Law, Maastricht University
      • Mr. Songezo Mabece, Legal Counsel, Competition Commission of South Africa
      • Professor Sope Williams-Elegbe, Professor of Law and Head of the Department of Mercantile Law, Deputy Director, African Procurement Law Unit, Stellenbosch University
      • Ms. Tan Jinghui, Lawyer
      • Mr. Timothy J. Farris, Senior Procurement Consultant, Debarment Solutions Institute LLC
      • Mr. Tomislav Šunjka, Principal and Founder, ŠunjkaLaw
      • Ms. Zhang Fang, Deputy Director, China International Contractors Association (CHINCA)

      The officers of the IBA’s Debarment and Exclusions Subcommittee deserve particular mention, including Co-Chairs Juan Ronderos and Roland Stein and Vice-Chairs Paul Kearney, Simon Laliberté, and Sope Williams-Elegbe. I wish to thank all the current and former project team members for the 2020 Survey within OSD, including Myles Ashong, Nikolaos Doukellis, Brittany Kouroupas, Caroline Wachtell, and Zeqing “Kate” Zheng, who put in a significant amount of time and effort finalizing the survey questions, receiving and reviewing survey responses, and preparing summaries for each jurisdiction.

      Thanks to my current OSD colleagues – Jamieson Smith, Gaukhar Larson, Alexandra Manea, Muslima Maksudzoda, and Haiyue “Stephanie” Xue – for your steadfast support of this initiative. Thanks should also go to the former interns and colleagues who moved this project along during their (much too) short time with OSD, including Shirin Ahlhauser, Nathaniel Castellano, Berk Guler, Sati Harutyunyan, and Eleanor Ross. Finally, a very special thank you to Pascale Hélène Dubois and Paul Ezzeddin for initially developing the idea for an exclusion survey back in 2015, giving life to this project, and ultimately having the confidence to allow me to continue moving the project forward. This Directory would not have happened without your efforts.

       

      Collin David Swan

      Project Lead, Global Suspension & Debarment Survey

      Senior Counsel (Sanctions), The World Bank Office of Suspension and Debarment

      Vice-Chair, IBA Debarment and Exclusions Subcommittee

       

    • Image

      The Global Suspension & Debarment Survey 2020:

      Understanding Exclusion Systems Around the World

      The Debarment and Exclusions Subcommittee of the International Bar Association’s Anti-Corruption Committee, in cooperation with the World Bank Office of Suspension and Debarment (“OSD”), the Sanctions Officer for the Inter-American Development Bank Group (comprised of the IDB, IDB Invest, and IDB Lab), and Le Bureau de l’inspecteur general de la Ville de Montréal, is conducted research into an array of national suspension & debarment (or “exclusion”) systems. We strove to compile as much data as possible to later serve as a consultative resource accessible to various stakeholders, including yourself.

      Contributions from local experts were integral to our goal of developing a comprehensive framework that identifies proven methodologies and best practices. The resulting data and related analysis, findings and recommendations were used to develop the Global Suspension and Debarment Directory.     

      The accompanying questionnaire strove to be as comprehensive as possible, and it consisted of over 60 questions. We asked respondents to only respond to those questions they felt comfortable answering and/or had time to answer. 

      Our inquiries explored the following topics in exclusion regimes:

      • Government-Wide Legal and Institutional Framework
      • Functioning and Enforcement of the Government-Wide Exclusion System
      • Substantive Grounds for Government-Wide Exclusion
      • Scope and Effect of Government-Wide Exclusion
      • Government-Wide Transparency: The Exclusion List
      • Limited Scope Exclusion Systems

      Download the survey here.

      Between May and October 2018, the Working Group launched and tested a pilot of the Global Suspension & Debarment Survey to formalize the questionnaire. Please click here to download the study's Survey Results. 

      Supplemental Material:

      El Salvador: Statutory Provisions

    • News & Events: 

      2021:

      On August 2, 2021, OSD published a piece announcing the Directory on The FCPA Blog. To read the blog click here.

      On July 29, 2021, OSD published a piece announcing the Directory on the World Bank’s Governance for Development blog. To read the blog click here.

      2020:

      On March 18, 2020, the International Bar Association (IBA) and the IBA Anti-Corruption Committee’s Debarment & Exclusions Subcommittee hosted a webinar on the Global Exclusion Survey. To watch the webinar, click here. 

      2019:

      On May 22, 2019, the George Washington Law Government Procurement Law Program and a Working Group of the IBA’s Anti-Corruption Committee hosted a presentation and discussion of the results of the Global Suspension & Debarment Survey pilot. A summary of the discussion can be found here.