Sanctions Evaluation and Suspension Officer
The World Bank Group

Pascale Helene Dubois is the Sanctions Evaluation and Suspension Officer (EO) for the World Bank. The sanctions process now consists of a two-tier process conducted by the EO and the World Bank Sanctions Board. The EO is the first tier in ensuring an efficient, effective and fair sanctions process for firms and individuals (Respondents) who are alleged to have engaged in fraud, corruption, collusion, coercion or obstructive practices (Misconduct) in relation to Bank-financed contracts. As EO, Ms. Dubois evaluates the evidence underlying the cases prepared by the World Bank Department of Institutional Integrity (INT); temporarily suspends corrupt companies’ contracts pending the final outcome of the case; and recommends a sanction (public debarment for a number of years, public reprimand, restitution, and/or compliance monitoring combined with other rehabilitative measures). Companies may contest the allegations and/or the recommended sanction by appealing to the Sanctions Board. Prior to becoming the EO in the spring of 2007, Ms. Dubois was managing the Voluntary Disclosure Program (VDP) in the Department of Institutional Integrity (INT). The VDP is an anti-corruption tool designed to improve aid effectiveness through the cooperation of participating firms that cease all misconduct and fully disclose information pertaining to their Misconduct to the World Bank in exchange for assurances of anonymity and no sanction. Before joining INT, Ms. Dubois worked for seven years in the Legal Department of the World Bank as Senior Counsel for the Africa Region. In that position, she focused on anti-corruption in Bank-financed projects and provided legal advice related to a variety of projects, including in the sectors of privatization, legal reform, private sector development, economic reform, health, education, water and energy.
Ms. Dubois came to the World Bank after a ten-year career in the private sector, based both in the United States and in Belgium. As an international corporate attorney, she specialized in international mergers and acquisitions, joint ventures, and strategic alliances in prestigious law firms and blue chip corporations in New York, Houston, Brussels and Washington, D.C.
Ms. Dubois speaks frequently at national and international events about the World Bank’s sanctions process and international anti-corruption issues.