First Conviction under the UK Bribery Act

Munir Patel

(Reuters) - The first person to be convicted under new bribery laws was jailed on Friday November 18th, 2011, and lawyers said his sentence sent out a warning message to business.

Munir Patel, 22, a court clerk who worked at Redbridge Magistrates' Court in east London, had pleaded guilty to accepting 500 pounds to "get rid" of speeding charges by keeping the details off a court database.

He was given three years in prison for bribery offences and six years for misconduct in a public office, with the sentences to run concurrently, the Press Association reported.

"The sentencing ... demonstrates the significant sentences that the courts are willing to impose on individuals who commit an offence under the (Bribery) Act," said Angela Pearson, a partner with international law firm Ashurst.

"It is only a matter of time before the SFO (Serious Fraud Office) bares its teeth and prosecutes the first corporate or its directors under the Act. In the meantime, the business community collectively hold their breath."

The Bribery Act, which came into force in July, makes failure to prevent bribery - whether committed by staff, subsidiaries or "associated persons" anywhere in the world - a criminal offence.

It also clamps down on so-called "facilitation payments," often used to oil the wheels of business by speeding up services such as visa applications, and "disproportionate" hospitality.

Southwark Crown Court heard Patel had helped at least 53 individuals evade prosecution for driving offences, and that he had advised people on how to avoid being summoned to court.

His salary was 17,978 pounds, but the court heard that 53,814 pounds in cash was deposited in his bank account while another 42,383 pounds was transferred into the same account, both without explanation.

"It hardly needs saying that these were very serious offences," Judge Alistair McCreath said.

"A justice system in which officials are prepared to take bribes in order to allow offenders to escape the proper consequences of their offending is inherently corrupt and is one which deserves no public respect and which will attract none."
(Reporting by Michael Holden; editing by Andrew Roche)

Australia Considering Criminalizing Facilitation Payments

Customer pays for a beer in central Sydney 21/06/2011 REUTERS/Tim Wimborne

Lawyers have welcomed the government's plans to bolster Australia's anti-bribery laws and outlaw facilitation payments, saying the changes would bring the country into line with international best practice and address the "weakest link" in the existing legislation.

In a consultation paper (PDF) launched yesterday the government outlined its proposals to remove the facilitation payments defence from s70.4 of the Criminal Code Act 1995. The reforms would align Australia's laws more closely with the UK's Bribery Act 2010, which took effect in July and has banned facilitation payments for UK-linked companies.

Unlike the UK and U.S., Australia does not have dedicated anti-bribery legislation. In Australia the act of bribing a foreign public official is proscribed under Division 70 of the Criminal Code. The legislation ensures that a person can be prosecuted under Australian law for "offering or providing a bribe to foreign public officials for the purpose of obtaining business or an undue business advantage". Like the UK and U.S. legislation it has extra-territorial effect and covers activities anywhere in the world.

In addition, Divisions 141 and 142 of the Criminal Code make it an offence to bribe a Commonwealth public official or for a Commonwealth public official to solicit a bribe.

Breaches of the legislation carry a maximum penalty of 10 years in prison and A$1.1 million fines for individuals and A$11m million in fines, or three times the benefit gained, for corporations. If the value of benefits obtained through bribery cannot be determined, the penalty for a company is 10 percent of annual turnover in cases where that amounts to more than A$1.1 million.

Brendan O'Connor, the minister for home affairs and justice, said there were strongly divergent views in Australia about the case for an exemption for facilitation payments. He said the purpose of the consultation was to get feedback from stakeholders about the merits or otherwise of removing the facilitation defence.

"I hear anecdotal evidence about the need to retain the defence because it is a reality of doing business, especially in the Asia-Pacific region," O'Connor said at the launch of the consultation paper. "I also note that, internationally, the defence of facilitation payments is gradually being removed from the criminal laws of our international trading partners. Maintaining the defence in Australia could appear incongruous with the aid and assistance message we send out in the region."

O'Connor said the government was aware that banning facilitation payments might put Australian businesses at a competitive disadvantage or in a "difficult situation" if payments were solicited under duress. It might also create an uneven playing field between large and smaller businesses. On the other hand, he said, it might also create greater consistency with the laws of other countries, promote regulatory certainty for businesses that operate across jurisdictions and help to reduce corruption globally. The government was also mindful that international developments, such as the commencement of the UK Bribery Act in July, had turned the tide against the facilitation payments defence.

Industry support

Within the legal and consulting sectors, there has been strong support for the government's decision to review the facilitation payments defence and other aspects of Australia's anti-bribery statutes.

Rob Locke, partner at Ernst & Young in Sydney, said that the latest consultation was further evidence of the global trend to take a harder line on facilitation payments. He said: "It is a timely and healthy initiative and a further sign that there is a global rethink about facilitation payments."

Christopher Keane, special counsel at Middletons, described the facilitation payment defence as the "weakest link" in Australia's foreign bribery legislation. He said the justifications for the defence were "tenuous at best" and said that businesses would be unwise to rely on this as part of their anti-bribery compliance frameworks.

"It is a very limited and complicated defence and is frequently misunderstood, thus exposing Australian businesses operating offshore to criminal liability in circumstances where they might genuinely believe they are acting lawfully," Keane said.

In essence, Keane said that there were three fundamental problems with the facilitation payments defence. "First, the defence is inconsistent with Australia's domestic laws. Secondly, the defence is inconsistent with the extra-territorial UK Bribery Act and the domestic laws of many of Australia's major trading partners. Thirdly, the most effective way for companies to avoid criminal liability arising under any anti-bribery legislation is to encourage a strong culture of compliance, whereas the facilitation payment defence is at the top of a very slippery slope that leads to serious criminal conduct," Keane said.

In view of all these issues, Keane said he was advising clients that Australian businesses should eliminate facilitation payments regardless of the outcome of the current consultation. "The safest approach is to proceed on the basis that there is no such thing as a facilitation payment defence," he said.

Extra-territorial impact

For Australian businesses that have links to the UK, the decision on proscribing facilitation payments has already been made. According to consultants at KPMG, Australian businesses with operations in the UK have already had to take a harder line on facilitation payments. These firms, as well as Australian subsidiaries of UK parent companies, are not only subject to the Australian anti-bribery laws but also to the requirements of the UK Bribery Act.

David Luijerink, partner at KPMG Forensic, said that those businesses with links to the UK could already be found guilty of an offence under the UK laws if they were unable to prove they had adequate procedures in place to prevent people from committing bribery. This applied not only to the activities of their employees but also to third-party associates, such as business partners, agents and contractors.

Luijerink noted: "It is important to note that the Act also covers the actions of non-UK nationals or residents. This means that an Australian business that transacts with the UK could very well find itself facing charges over illegal conduct by a non-British employee or a contractor, or for failing to prevent a third-party supplier from paying or receiving a bribe, even if the misconduct took place in another country."

He added that, under the new legislative landscape, firms would not be able to claim they were ignorant of facilitation payments that were happening under their watch. "Businesses need to cultivate a deeper culture of compliance and be able to demonstrate that they have sufficient risk management practices embedded in the business to mitigate bribery risks. Citing corporate ignorance in this instance will offer no protection from the long reach of the Act," Luijerink said.

A recent report from KPMG, entitled the "Global Anti-Bribery and Corruption Survey 2011", revealed that one third of businesses in the UK and U.S. did not assess the risk of bribery or corruption. Of those with written anti-bribery and corruption policies, 40 percent did not distribute them to relevant third parties and 60 percent did not require third-party representatives to participate in anti-bribery compliance training.

The survey also found that most anti-bribery and corruption compliance programs lacked sufficient depth and breadth to offset any regulatory risk effectively.

Luijerink said: "The potential costs of involvement in bribery and corruption are not limited to economic costs but also extend to reputational harm, and businesses need to weigh up whether not complying with the Act is a risk they can afford."

Broader discussion

Consultants and lawyers have said that, in Australia, the reform of the anti-bribery laws will have to take into account all of these major international developments. As well as the facilitation payments issue, the review of Divisions 70 and 141 of the Criminal Code will also explore a number of related issues regarding the anti-bribery statutes. Under the existing laws, courts must disregard the value of a benefit when determining whether a benefit was "legitimately due". This is to ensure that bribery is an offence irrespective of the value of the benefit.

As an example, the consultation paper stated that there might be situations where a person would be legitimately due a moderate fee in return for providing a particular service connected with obtaining business. "However, in the same situation a very large fee may be highly improper and not legitimately due to the public official or other person," it stated.

The government is considering whether to change para 70.2(2)(b) to clarify that bribery is an offence irrespective of the value of the benefit offered or given.

The consultation has also looked at changing the laws to ensure that prosecutions can proceed where a recipient of a bribe cannot be identified. To achieve this, the laws would need to be changed so that it is not necessary to prove an intention to influence a particular official. This will ensure that the law covers circumstances where a bribe is paid but the particular official to whom the bribe was destined cannot be identified.

The consultation paper stated: "For example, it may be possible to prove a person offered or provided a bribe to an agency in charge of granting public infrastructure contracts, but not possible to identify whether the payment is destined for the official directly responsible for granting contracts or another official who will direct their staff to grant a certain contract."

The final significant reform would be to change the laws so that "dishonesty" was not a requirement of the domestic bribery offence. Under the foreign bribery laws (Division 70) there is an obligation to demonstrate that bribery was committed intentionally but not necessarily "dishonestly". The government has proposed to align the offences in Divisions 141 and 142 with Division 70 by removing the "dishonesty" requirement from these offences, which would assist with the harmonisation of domestic and foreign bribery offences.

The paper noted that "the requirement in Divisions 141 and 142 to prove dishonesty as well as bribery could make it more difficult to prosecute crimes of domestic corruption".

O'Connor said that stakeholders should make the most of the opportunity to improve Australia's anti-bribery laws and to bring them more closely into line with those in other jurisdictions.

"While we consider that we have strong laws to combat foreign bribery, we want to examine our legislation in light of international developments and hear from you about the reality of doing business beyond our shores," he said.

Responses to the consultation paper (PDF) need to be lodged by December 15, 2011.

(A$1 = US$1.01)

United Kingdom: Redefining The Criminal Cartel Offence

This article was first published in Competition Law Insight, 18 October 2011. Corker Binning is a law firm specialising in fraud, regulatory litigation and general criminal work of all types. For further information go to http://www.corkerbinning.com

In March 2011 the government published a lengthy consultation paper which set out proposals for a wide-ranging reform of the UK competition regime. One section of this consultation paper was devoted to the criminal cartel offence under the Enterprise Act 2002. The government argued that the need to prove dishonesty as an element of this offence had made prosecutions too difficult and, in consequence, the introduction of the offence in 2003 had not had the intended deterrent effect. The paper puts forward four options for a new model offence with a preference for the one which would criminalise secret price-fixing agreements with no requirement to prove dishonesty as a specific ingredient of the offence. But is this the right approach and is it too soon to be proposing such a radical change?
The government's proposals attracted a large number of responses. A quick survey shows them to be uniformly hostile to the removal of the dishonesty element. They almost all make the same central point: paucity of cases is not necessarily an indication that the regime is not functioning well. To put this another way, there is insufficient evidence to establish that the dishonesty element has led to otherwise strong cases not being brought to court.

The OFT's mediocre record to date

Plainly the OFT's performance in relation to prosecutions of this offence is a matter of legitimate public concern. In the last eight years there have only been two prosecutions. And in the only one of these which was contested (BA-Virgin or R v George), the OFT's case collapsed because of its inadequate capability to deal with certain investigatory procedures. So on the face of it, enforcement of this offence is not working out as the government intended.
However, a fair appreciation of the OFT's record needs to take account of three important factors - all of which work against the bringing of prosecutions. First, in the realm of competition law enforcement generally, the main weapon available to regulators is leniency. In common with the US approach, the OFT believes that the best means to achieve compliance is a clear policy which encourages cartel participants to report themselves. This is underpinned by the opportunity to achieve a non-prosecution outcome in some cases. So a lack of prosecutions may in fact be a measure of the OFT's success. In order to fairly determine this, what is needed is an evaluation of the leniency applications made since 2003 to see how many of them were made partly out of a desire to limit the threat of a prosecution.
Secondly, as the international record of criminal cartel enforcement demonstrates, the majority of alleged cartels which are selected for prosecution are, for reasons beyond the scope of this article, bipartite ones. Unlike civil litigation, prosecutions tend to be of one set of participants connected to company A with the other set connected to Company B being immunised prosecution witnesses, as in the BA-Virgin case. As any prosecutor well knows, a case built on the purported credibility and honesty of witnesses from A whose evidence has only been obtained as a result of an immunity deal and whose conduct was the same as the accused from B will always be a risky one. The witnesses may turn sour on the prosecutor and the court may regard the prosecution with distaste taking account of the fact that pragmatism has apparently scored over principle and that the accused have palpably been singled out for prosecution whilst the others happened to do a deal which meant they escaped justice so long as they heaped blame on the accused. Whilst these problems may also infect a more multi-party case, the mirror-image issue is unlikely to be as pronounced.
Thirdly, the likelihood is that most cartel investigations are multi-jurisdictional with the implication that what one enforcer does in one country is likely to shape the approach of others. A decision made in, for example, the US by the cartels section of the Department of Justice to settle a case via a non-prosecution agreement is likely to fetter the ability of the OFT to prosecute anyone concerned in the same alleged cartel. So an antecedent and often uncoordinated decision by one prosecutor to extend leniency can lead to other prosecutors having to accept they have to act likewise. This is not a problem confined to cartels; much of the SFO's work concerning overseas corruption has been stymied by an announcement made in Washington DC that the criminal investigation there is all over.
Rather than considering changes to the offence itself, it may be better to look instead at measures designed to improve the OFT's capacity to bring cartel prosecutions successfully. Indeed this in essence was the conclusion reached by the OFT itself in its Project Condor Board Review published in December 2010. Undoubtedly the OFT has sought to implement many of its recommendations and some time must elapse before they bear fruit. Criminal cartel investigations take a long time as the subject-matter is invariably complex; for example on 4 October 2011, the OFT announced it had dropped its probe of a company executive (just one) in the automotive components industry having first arrested him in February 2010.

Why the dishonesty element is worth preserving

When the offence was first mooted by the then government and later considered during the Act's legislative passage, this element and the rationale for its inclusion in the new offence attracted considerable attention and debate. It did not slip into the Act during a late night parliamentary sitting or, like SOCPA 2005 which created the now to be abolished SOCA, get nodded through in a parliamentary rush on the eve of a general election. The case for change as now advocated should begin with the issue of whether it is proper in relation to an offence which alleges serious criminality and in respect of which the maximum penalty is five years' imprisonment, that there should no longer be any need to establish an accused's dishonesty.
If a reworded cartel offence did not include the requirement to prove dishonesty, this would constitute a remarkable and troubling exception to the tradition of English criminal law when serious criminal conduct is involved. In economic crime, the offences applicable to the serious criminal conduct of individuals created either by the common law (such as conspiracy to defraud and offences of cheating the public revenue) or by statute (such as the Fraud Act 2006) have all included an element of conscious impropriety. Whilst this mental element may be expressed in slightly different terms in the calendar of offences falling within the rubric of economic crime, essentially they mostly require proof of dishonesty. One cannot defraud or cheat by mere recklessness or negligence. Of course there are offences of strict liability applicable to individuals as well as companies but these tend to be summary only offences where the conduct is not nearly so serious as in the more serious offences such as criminal cartel activity.
The creation of new criminal offences has usually been preceded by a public consensus that the conduct to be criminalised is that which the majority of the public regard as nefarious or seriously harmful to the public interest. If the government contends that a criminal offence needs to be made easier to prove because a jury will otherwise not convict, one must ask whether such reluctance reflects a widespread perception that the conduct should not be prosecuted at all. So in the case of the cartel offence, is the perceived difficulty about proving dishonesty rooted in a fear that the public generally believe that anti-competitive activity is best sanctioned by the civil and not criminal law? Without a jury ever having had the opportunity to consider a verdict in respect of this offence, this question remains a real one.
The proposals also fail to take into account the detailed consideration given to the reform of the law on fraud by the Law Commission in its 2002 report which gave rise to the Fraud Act 2006. Instead, it refers to an earlier 1999 Law Commission report. In its 2002 report, the Law Commission found that the R v Ghosh definition of dishonesty is unproblematic for jurors - a vital element of a large number of criminal offences - and that to abandon it would have a significant impact on the criminal justice system.

The government's four options for reform

Whilst it is argued that none of these proposals for reform are superior to the current offence, each requires a brief mention.

• Reliance on prosecutorial guidance. The DPP's recent guidance on prosecuting cases of assisting suicide may be analogous. But do we want to rely on prosecutors to tell us what should be a tort and what should be an offence? It becomes very difficult for a prosecutor to fairly distinguish one form of alleged "hard-core" cartel behaviour from another and so decide which to take no action against and which to prosecute. Surely it is preferable that the statute defines the offence and that the current formula of requiring cogent evidence of dishonesty is a suitable way of discriminating one alleged cartel from another?

• Excluding the offence for a list of virtuous or "white-listed" price-fixing agreements. It is difficult to see how such an approach would avoid the vice of uncertainty. Surely any purportedly benign agreement would be pro not anti-competitive and establishing this would invite a plethora of expert evidence into the criminal courtroom. Moreover, the burden of proving this would inevitably be cast onto the accused.

• A secrecy criterion. Such an element would be a novel one for our criminal jurisprudence in contrast to the settled law on dishonesty. Distinguishing legitimate confidentiality in commercial transactions from the concept of secrecy would seem a difficult test to apply in reality and thus allow for lawyers to endlessly argue it is the former not the latter. And why should secrecy be the proper moral foundation for distinguishing civil from criminal conduct?

• Defining the offence to exclude agreements made openly. But "openly" in relation to whom? The immediate customer who may be another wholesaler able to absorb a price increase by passing it on, or the ultimate retail customer unable to easily do so? Surely the kinds of cartels which most deserve prosecution are those which harm individual consumers, in relation to whom the concept of agreements between suppliers made openly or not has no application.

Conclusion

There is plenty of cartel activity around the world but national and regional competition regimes vary considerably in the enforcement tools available to them. Criminal penalties do operate as significant deterrents if they are backed up by real cases coming to court. In the UK at least, the criminal cartel regime needs time to develop with more resources for investigation and prosecution. Removing dishonesty as an element of the cartel offence is an easy option but it may not speed up investigations or make prosecutions before juries easier. The government may have its work cut out to come up with a better regime than the one we have at present.


The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

IDB List of Sanctioned Firms and Individuals

The firms and individuals listed below have been sanctioned by the IDB Group’s Sanctions Committee because they were found to have engaged in fraud, corruption, collusion or coercion, in violation of the IDB Group’s anti-corruption policies. These findings were made through an administrative process that permitted the accused firms and/or individuals to respond to the allegations pursuant to the Sanctions Procedures. Sanctions are meant to prevent and deter fraud and corruption in IDB Group-financed activities. 

The Sanctions Committee may impose any sanction that it deems to be appropriate under the circumstances, including but not limited to reprimand, conditions on future contracting and debarment. Debarred firms are declared ineligible to be awarded and participate in any IDB-financed contract for the periods indicated. Ineligibility may extend to any firm or individual who directly or indirectly controls the debarred firm or any firm which the debarred firm directly or indirectly controls. In the case of a debarred individual, ineligibility may extend to any firm which the debarred individual directly or indirectly controls.

IDB Group's list of Sanctioned Firms and Individuals

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Name	Entity Type/Nationality	Title Affiliation	Country of Project	Ineligibility From	Ineligibility To	Grounds
Öztaþ Ýnþaat inþaat Malzemeleri Ticaret Anonim Þirketi of Iller Sokak	Corporation/Turkey		Georgia	9/26/20111	9/26/2014	Fraudulent Practices, Cross-Debarment notice from the World Bank
Glosolve Limited	Corporation/United Kingdom		Mongolia	04/01/2014	03/31/2018	Fraudulent Practices, Cross-Debarment notice from the World Bank
Global Technology Solutions, Inc	Corporation/USA		Mongolia	04/01/2014	03/31/2018	Fraudulent Practices, Cross-Debarment notice from the World Bank
The Glocoms Group, Inc.	Corporation/USA		Mongolia	04/01/2014	03/31/2018	Fraudulent Practices, Cross-Debarment notice from the World Bank
Maurence Anguh	Person/USA		Mongolia	04/01/2014	03/31/2018	Fraudulent Practices, Cross-Debarment notice from the World Bank
Glocoms, Inc	Corporation/USA		Mongolia	04/01/2014	03/31/2018	Fraudulent Practices, Cross-Debarment notice from the World Bank
Gregory Ilias Lee also known as Greg Lee or Gregory Lee	Individual/Australia	Individual	Indonesia	08/02/2011	08/01/2014	Fraudulent Practices - Cross Debarment from The World Bank
Hefei Highway & Bridge Project Co. Ltd.	Firm/China		China	06/28/2011	06/27/2013	Fraudulent Practices - Cross Debarment from The World Bank
Human Resources Development Organization (HURDO)	Firm/Bangladesh		Bangladesh	07/29/2011	07/28/2015	Fraudulent Practices - Cross Debarment from The World Bank
Mr. Md. Shamul Alam	Individual/Bangladesh		Bangladesh	07/29/2011	07/28/2015	Fraudulent Practices - Cross Debarment from The World Bank
Lasservice NV	Firm/Belgium		Gambia	06/03/2011	06/02/2013	Fraudulent Practices - Cross Debarment from The World Bank
Mr. Joseph Nuijten	Individual/Belgium		Gambia	06/03/2011	06/02/2013	Fraudulent Practices - Cross Debarment from The World Bank
Marvel Novedi	Firm/France		Democratic Republic of Congo	07/26/2011	07/25/2014	Fraudulent Practices - Cross Debarment from The World Bank
Marvel SA	Firm/France		Democratic Republic of Congo	07/26/2011	07/25/2014	Fraudulent Practices - Cross Debarment from The World Bank
Marvel SAS	Firm/France		Democratic Republic of Congo	07/26/2011	07/25/2014	Fraudulent Practices - Cross Debarment from The World Bank
Societe Marvel	Firm/France		Democratic Republic of Congo	07/26/2011	07/25/2014	Fraudulent Practices - Cross Debarment from The World Bank
Dr. Hans Peter Schone	Individual/Germany		Russia	08/17/2011	08/16/2016	Fraudulent Practices - Cross Debarment from The World Bank
Proveeduría Medica	Firm/Argentina		Argentina	06/16/2011	06/15/2014	Fraudulent Practices - Cross Debarment from The World Bank
Association Muhandison	Firm/Tajikistan		Tajikistan	06/01/2011	05/31/2014	Fraudulent Practices - Cross Debarment from The World Bank
LLC UN&CO	Firm/Tajikistan		Tajikistan	06/01/2011	05/31/2014	Fraudulent Practices - Cross Debarment from The World Bank
Mr. K. M. Rahman	Individual/Bangladesh		Bangladesh	07/29/2011	07/28/2015	Fraudulent Practices - Cross Debarment from The World Bank
Samajik Sangha (SS)	Firm/Bagladesh		Bangladesh	07/29/2011	07/28/2015	Fraudulent Practices - Cross Debarment from The World Bank
Sego Ventures Nigeria Limited	Firm/Nigeria		Nigeria	06/03/2011	06/02/2013	Fraudulent Practices - Cross Debarment from The World Bank
Mrs. Shamsunnahar	Individual/Bangladesh		Bangladesh	08/22/2011	08/21/2015	Fraudulent Practices - Cross Debarment from The World Bank
Development Action Centre (DAC)	Firm/Bangladesh		Bangladesh	08/22/2011	08/21/2015	Fraudulent Practices - Cross Debarment from The World Bank
Mr. Sealtiel Orozco	Individual/Nicaragua		Nicaragua	08/23/2011	08/22/2013	Fraudulent Practices - Cross Debarment from The World Bank
Telecomunicaciones y Sistemas S.A.	Firm/Nicaragua		Nicaragua	08/23/11	08/22/2013	Fraudulent Practices - Cross Debarment from The World Bank
Karma Mara, Indonesia	Individual/Indonesia		Indonesia	05/17/2011	05/16/2013	Non-specified Practices - Cross-debarment from The Asian Development Bank
Tiyasa Suwarly M	Individual/Indonesia		Indonesia	05/17/2011	05/16/2017	Non-specified Practices - Cross-debarment from The Asian Development Bank
lr. Widhiastoto	Individual/Indonesia		Indonesia	05/17/2011	05/16/2017	Non-specified Practices - Cross-debarment from The Asian Development Bank
Akhtar M. Babul M	Individual/Bangladesh		Bangladesh	05/17/11	05/16/15	Non-specified Practices - Cross-debarment from The Asian Development Bank
PT Multi Area Conindo	Firm/Indonesia		Indonesia	05/17/2011	05/16/2017	Non-specified Practices - Cross-debarment from The Asian Development Bank
YANG LIN	Individual/China		Sudan	05/11/2011	05/10/2014	Fraudulent Practices - Cross-Debarment from The World Bank
Zhejiang Zheda Insigma Technology Co. Ltd	Firm/China		Bulgaria	08/01/2011	07/31/2014	Fraudulent Practices - Cross-Debarment from the European Bank for Reconstruction and Development
Zhejiang Zheda Insigma Group Co. Ltd.	Firm/China		Bulgaria	08/01/2011	07/31/2014	Fraudulent Practices - Cross-Debarment from the European Bank for Reconstruction and Development
Idreco S.p.A	Firm/Italy		Bulgaria	08/01/2011	07/31/2014	Fraudulent Practices - Cross-Debarment from the European Bank for Reconstruction and Development
Idreco Invest S.p.A.	Firm/Italy		Bulgaria	08/01/2011	07/31/2014	Fraudulent Practices - Cross Debarment from the European Bank for Reconstruction and Development
SDC Consulting Co. Limited Cambodia	Firm/Cambodia		N/A	07/12/2011	07/11/2021	Fraudulent Practices - Cross Debarment from the Asian Development Bank
Sustainable Development Consultants Cambodia Limited	Firm/Cambodia		N/A	07/12/2011	07/11/2021	Fraudulent Practices - Cross Debarment from the Asian Development Bank
Ly Moni Roth	Individual/Cambodia		N/A	07/12/2011	Indefinite	Fraudulent Practices - Cross Debarment from the Asian Development Bank
Syani Phirom	Individual/Cambodia		N/A	07/12/2011	Indefinite	Fraudulent Practices - Cross Debarment from the Asian Development Bank
Sukhjin Co. Ltd	Firm/Mongolia		N/A	07/12/2011	07/11/2018	Fraudulent Practices - Cross-Debarment from the Asian Development Bank
Luis Adolfo Pérez Obregón	Individual/Nicaragua		Nicaragua	06/22/2011	06/22/2013	Fraudulent practices, Art. 5.02 (c)(iii) General Conditions Contract Agreement 1702/SF-NI
Teresa Antonia Pérez Brenes	Individual/Nicaragua		Nicaragua	06/22/2011	06/22/2013	Fraudulent practices, Art. 5.02 (c)(iii) General Conditions Contract Agreement 1702/SF-NI
Luis Adolfo Pérez Brenes	Individual/Nicaragua		Nicaragua	06/22/2011	06/21/2016	Fraudulent practices, Art. 5.02 (c)(iii) General Conditions Contract Agreement 1702/SF-NI
Empresa Constructora Luis Pérez Brenes S.A.	Firm/Nicaragua		Nicaragua	06/22/2011	06/22/2016	Fraudulent practices, Art. 5.02 (c)(iii) General Conditions Contract Agreement 1702/SF-NI
Mario Alirio Palacios Quiceno	Individual/Colombia		Colombia	06/22/2011	06/22/2014	Fraudulent practices, Art. 5.02 (c)(ii) General Conditions Contract Agreement 1950/OC-CO
Gabriel Jean-Charles	Individual/Haiti		Haiti	06/22/2011	06/22/2021	Corruptive practices. Art 5.02 (c)(i) General Conditions Contract Agreement 1491/SF-HA
Marylyn Paul Theodore	Individual/Haiti		Haiti	06/22/2011	06/22/2016	Corruptive practices. Art 5.02 (c)(i) General Conditions Contract Agreement 1491/SF-HA
Ronald Theodore	Individual/Haiti		Haiti	06/22/2011	06/22/2016	Corruptive practices. Art 5.02 (c)(i) General Conditions Contract Agreement 1491/SF-HA
Chantiers Modernes d'Haiti	Firm/Haiti		Haiti	06/22/2011	06/22/2016	Corruptive practices. Art 5.02 (c)(i) General Conditions Contract Agreement 1491/SF-HA
Marcos Mario Medina Castillo	Individual/Bolivia	Legal Representative of Fokus Proyecciones	Bolivia	03/22/2011	03/22/2014	Fraudulent practices, Art. 5.02 (c)(iii) General Conditions Contract Agreement 1091/SF-BO
Fokus Proyecciones	Firm/Bolivia		Bolivia	03/22/2011	03/22/2014	Fraudulent practices, Art. 5.02 (c)(iii) General Conditions Contract Agreement 1091/SF-BO
Gean Carlo Gutiérrez Morón	Individual/Peru		Peru	03/22/2011	03/22/2014	Fraudulent practices, Art. 5.02 (c)(iii) General Conditions Contract Agreement 1591/OC-PE
Pedro Miguel Távara Salazar	Individual/Peru		Peru	03/22/2011	03/22/2014	Fraudulent practices, Art. 5.02 (c)(iii) General Conditions Contract Agreement 1591/OC-PE
Miguel Ángel Zárate Mardueño	Individual/Mexico	Legal Representative of Moctezur Construcciones S.A. de C.V. (MOCTEZUR)	Mexico	03/03/2011	03/03/2014	Fraudulent practices. Art. 3.1 (a)(iii)General Conditions applicable to the Tender Documents. Contract Agreement 1744/OC-ME
Moctezur Construcciones S.A. de C.V. (MOCTEZUR)	Firm/Mexico		Mexico	03/03/2011	03/03/2014	Fraudulent practices. Art. 3.1 (a)(iii)General Conditions applicable to the Tender Documents. Contract Agreement 1744/OC-ME
Abraham de Jesús Berrios Hernández	Individual/Guatemala	Legal Representative of Administradora de Marcas S.A.	Guatemala	03/02/2011	03/02/2014	Fraudulent practices. Art. 1.14 (a)(ii)General Conditions Contract Agreement 1469/OC-GU
Administradora de Marcas S.A.	Firm/Guatemala		Guatemala	03/02/2011	03/02/2014	Fraudulent practices. Art. 1.14 (a)(ii)General Conditions Contract Agreement 1469/OC-GU
Lenin Medina Porras	Individual/Mexico	Legal Representative of Probain de Occidente SRL de C.V. (PROBAIN)	Mexico	02/07/2011	02/07/2014	Fraudulent practices, Art. 5.02 (c)(ii) General Conditions Contract Agreement 1383/OC-ME
Probain de Occidente SRL de C.V. (PROBAIN)	Firm/Mexico		Mexico	02/07/2011	02/07/2014	Fraudulent practices, Art. 5.02 (c)(ii) General Conditions Contract Agreement 1383/OC-ME
Gustavo Cimar Unzueta Sossa	Individual/Bolivia		Bolivia	02/07/2011	Permanent	Corruptive practices. Art 5.02 (c)(i) General Conditions Contract Agreement 1075/SF-BO
José Luis Valadez	Individual/Mexico	Legal Representative of Constructora y Arrendadora Cogral, S.A. de C.V.	Mexico	02/07/2011	02/07/2014	Fraudulent practices, Art. 5.02 (c)(ii) General Conditions Contract Agreement 1744/OC-ME
Constructora y Arrendadora Cogral, S.A. de C.V.	Firm/Mexico		Mexico	02/07/2011	02/07/2014	Fraudulent practices, Art. 5.02 (c)(ii) General Conditions Contract Agreement 1744/OC-ME
Constructora Carrera	Firm/Guatemala		Guatemala	02/07/2011	02/07/2014	Fraudulent practices, Art. 5.02 (c)(ii) General Conditions Contract Agreement 1469/OC-GU
Israel Carrera Palencia	Individual/Guatemala	Legal Representative of Constructora Carrera	Guatemala	02/07/2011	02/07/2014	Fraudulent practices, Art. 5.02 (c)(ii) General Conditions Contract Agreement 1469/OC-GU
Gerardo Rafael Barreto Maldonado	Individual/Bolivia		Bolivia	01/20/2011	01/20/2014	Fraudulent practices, Art. 5.02 (c)(ii) General Conditions Contract Agreement 1557/SF-BO
Víctor Juan Pereira	Individual/Bolivia	General Manager of Ingeniería Prefabricados y Construcción S.R.L. - IPRECO	Bolivia	01/20/2011	01/20/2016	Fraudulent practices, Art. 5.02 (c)(ii) General Conditions Contract Agreement 1557/SF-BO
Ingeniería Prefabricados y Construcción S.R.L. - IPRECO	Firm/Bolivia		Bolivia	01/20/2011	01/20/2016	Fraudulent practices, Art. 5.02 (c)(ii) General Conditions Contract Agreement 1557/SF-BO
Ramón Enrique Moreno	Individual/Honduras		Honduras	01/21/2011	01/21/2014	Corruptive practices. Art 5.02 (c)(i) General Conditions Contract Agreement 1059/SF-HO
Leonardo Morales Ordoñez	Individual/Ecuador		Ecuador	10/08/2010	10/08/2013	Corruptive practices. Art 5.02 (c) General Conditions Contract Agreement 1802/OC-EC
Escuela Andaluza de Salud Pública (EASP)	Firm/España		Argentina	09/15/2010	09/15/2013	Corruptive practices. Art 5.02 (c)(i) General Conditions Contract Agreement 1193/OC-AR
Juan José Pérez Brenes	Individual/Nicaragua	Legal Representative of Compañía Ing. Juan José Pérez Brenes	Nicaragua	09/15/2010	09/15/2013	Fraudulent practices, Art. 5.02 (c)(iii) General Conditions Contract Agreement 1100/SF-NI
Carlos Fernando Laje	Individual/Argentina		Argentina	09/15/2010	09/15/2015	Fraudulent practices, Art. 5.02 (c)(iii) General Conditions Contract Agreement 1193/OC-AR
Enrique Eduardo Rozenblat	Individual/Argentina		Argentina	09/15/2010	09/15/2015	Fraudulent practices, Art. 5.02(c)(iii) General Conditions Contract Agreement 1193/OC-AR
Proveedora Ferretera	Firm/Honduras		Honduras	5/3/2010	Permanent	Fraudulent practices, Art. 5.02 (c)(iii) General Conditions Contract Agreement 1077/SF-HO
Ramon de Jesus Flores Castro	Individual/Honduras	Legal representative and general manager of Proveedora Ferretera	Honduras	5/3/2010	Permanent	Fraudulent practices, Art. 5.02 (c)(iii) General Conditions Contract Agreement 1077/SF-HO
Juan José Zavala Reyes	Individual/Nicaragua	Legal Representative of Construcciones Alaniz y Compañía Limitada	Nicaragua	4/5/2010	4/5/2013	Fraudulent practices, Art. 5.02 (c)(iii) General Conditions Contract Agreement 1702/SF-NI
Judith Leticia Ayala Talavera	Individual/Paraguay		Paraguay	4/5/2010	4/5/2013	Fraudulent practices, Art. 5.02 (c)(iii) General Conditions Contract Agreement 1448/OC-PR
Compañia de la Construccion Sociedad Anonima de Capital Variable – CODECON S.A. de C.V.	Firm/Honduras		Honduras	3/19/2010	Permanent	Fraudulent practices, Art. 5.02 (c)(iii) General Conditions Contract Agreement 1048/SF-HO
Vladimir Su Yañez	Individual/Honduras	Legal Representative of Compañia de la Construccion Sociedad Anonima de Capital Variable – CODECON S.A. de C.V.	Honduras	3/19/2010	Permanent	Fraudulent practices, Art. 5.02 (c)(iii) General Conditions Contract Agreement 1048/SF-HO
S y S Ingeniería y Consultoría Ltda.	Firm/Colombia		Colombia	3/19/2010	3/19/2013	Fraudulent practices, Art. 5.02 (c)(iii) General Conditions Contract Agreement 1825/OC-CO
Janeth Patricia Sanabria Rodríguez	Individual/Colombia	Legal Representative of S y S Ingeniería y Consultoría Ltda.	Colombia	3/19/2010	3/19/2013	Fraudulent practices, Art. 5.02 (c)(iii) General Conditions Contract Agreement 1825/OC-CO
Juan Carlos Sanabria Rodríguez	Individual/Colombia	Engineer of S y S Ingeniería y Consultoría Ltda.	Colombia	3/19/2010	3/19/2013	Fraudulent practices, Art. 5.02 (c)(iii) General Conditions Contract Agreement 1825/OC-CO
Juan Domingo Tablares Aliaga	Individual/Bolivia		Bolivia	7/10/2009	Permanent	Fraudulent and extortionary practices, Art. 6 (d)(ii) (iii), Applicable Norms to Technical Cooperation ATN/ME-9627-BO
José Raymundo Velásquez Zepeda	Individual/Honduras		Honduras	7/10/2009	7/10/2012	Fraudulent practices, Art. 5.02 (c)(iii) General Conditions Contract Agreement 1115/SF-HO
Felipe Edgardo Oyuela Silva	Individual/Honduras		Honduras	7/10/2009	7/10/2012	Fraudulent practices, Art. 5.02 (c)(iii) General Conditions Contract Agreement 1115/SF-HO
Nicolás Javier Meléndez Velásquez	Individual/Honduras		Honduras	7/10/2009	7/10/2012	Fraudulent practices, Art. 5.02 (c)(iii) General Conditions Contract Agreement 1115/SF-HO
Ivar Demóstenes Castellanos Ibañez	Individual/Bolivia		Bolivia	6/30/2009	6/30/2012	Fraudulent practices, Art. 5.02 (c)(iii) General Conditions Contract Agreement 1057/SF-BO
Martín Javier Battiti	Individual/Honduras		Honduras	6/30/2009	6/30/2014	Fraudulent practices, Art. 5.02 (c)(iii) General Conditions Contract Agreement 1059/SF-HO
Raúl Pernia Ruíz	Individual/Colombia		Colombia	6/15/2009	6/15/2013	Fraudulent practices, Art. 5.02 (c)(iii) General Conditions Contract Agreement 910/OC-CO
Ricardo Augusto Reynoso González	Individual/Guatemala	General Manager, Vice President, Partner and Legal Representative of Sistemas de Investigación de Mercados, SA (SIM)	Guatemala	6/15/2009	Permanent	Fraudulent practices, Art. 6 (d) (iii), Applicable Norms to Technical Cooperation ATN/ME-6537-GU
Hans Estuardo Caderón Palacios	Individual/Guatemala	Project Supervisor and Sub-coordinator	Guatemala	6/15/2009	Permanent	Fraudulent practices, Art. 6 (d) (iii), Applicable Norms to Technical Cooperation ATN/ME-6537-GU
Acceso, Accesorios, Complementos y Servicios	Firm/Guatemala		Guatemala	3/12/2009	3/12/2014	Collusive Practices, Art. 5.02 (c)(iv) General Conditions Contract Agreement 1331/OC-GU
Luis Rafael Guerra Sandoval	Individual/Guatemala	Owner of Acceso, Accesorios, Complementos y Servicios	Guatemala	3/12/2009	3/12/2014	Collusive Practices, Art. 5.02 (c)(iv) General Conditions Contract Agreement 1331/OC-GU
Proyectos Elite	Firm/Guatemala		Guatemala	3/12/2009	3/12/2014	Collusive Practices, Art. 5.02 (c)(iv) General Conditions Contract Agreement 1331/OC-GU
Marvin Estuardo Escobar Ruano	Individual/Guatemala	Owner of Proyectos Elite	Guatemala	3/12/2009	3/12/2014	Collusive Practices, Art. 5.02 (c)(iv) General Conditions Contract Agreement 1331/OC-GU
Maquimar S.A.	Firm/Guatemala		Guatemala	3/12/2009	3/12/2014	Collusive Practices, Art. 5.02 (c)(iv) General Conditions Contract Agreement 1331/OC-GU
Francisco Javier Martinez Espinoza	Individual/Guatemala	Owner of Maquimar S.A.	Guatemala	3/12/2009	3/12/2014	Collusive Practices, Art. 5.02 (c)(iv) General Conditions Contract Agreement 1331/OC-GU
Consultora Tecnodinámica S.R.L.	Firm/Paraguay		Paraguay	2/9/2009	Permanent	Fraudulent Practices, Art. 5.02 (c)(iii) General Conditions Contract Agreement 1278/OC-PR
Consultora Guaraní S.A. Ingenieros Civiles	Firm/Paraguay		Paraguay	2/9/2009	Permanent	Fraudulent Practices, Art. 5.02 (c)(iii) General Conditions Contract Agreement 1278/OC-PR
Consorcio Tecnodinámica y Asociados	Firm/Paraguay		Paraguay	2/9/2009	Permanent	Fraudulent Practices, Art. 5.02 (c)(iii) General Conditions Contract Agreement 1278/OC-PR
Graciela Beatriz Modesto Merlo	Individual/Paraguay	Legal Representative of Consultora Guaraní	Paraguay	2/9/2009	Permanent	Fraudulent Practices, Art. 5.02 (c)(iii) General Conditions Contract Agreement 1278/OC-PR
Julio Vicente Ullón Espinola	Individual/Paraguay	Legal Representative of Consultora Tecnodinámica	Paraguay	2/9/2009	Permanent	Fraudulent Practices, Art. 5.02 (c)(iii) General Conditions Contract Agreement 1278/OC-PR
Pericles Modesto Schussmuller	Individual/Paraguay	Legal Representative of Consultora Guaraní	Paraguay	2/9/2009	Permanent	Fraudulent Practices, Art. 5.02 (c)(iii) General Conditions Contract Agreement 1278/OC-PR
José Gustavo Modesto Merlo	Individual/Paraguay	Legal Representative of Consultora Guaraní	Paraguay	2/9/2009	Permanent	Fraudulent Practices, Art. 5.02 (c)(iii) General Conditions Contract Agreement 1278/OC-PR
Constructora RGH Contratistas Generales S.R.L.	Firm/Perú		Perú	2/9/2009	2/9/2012	Fraudulent Practices, Art. 5.02 (c)(iii) General Conditions Contract Agreement 1325/OC-PE
Consorcio Leoncio Cárdenas Morán y Constructora RGH Contratistas Generales S.R.L.	Firm/Perú		Perú	2/9/2009	2/9/2012	Fraudulent Practices, Art. 5.02 (c)(iii) General Conditions Contract Agreement 1325/OC-PE
Richard Guevara Herrera	Individual/Perú	Manager of Constructora RGH Contratistas Generales S.R.L.	Perú	2/9/2009	2/9/2012	Fraudulent Practices, Art. 5.02 (c)(iii) General Conditions Contract Agreement 1325/OC-PE
Leoncio Cárdenas Morán	Individual/Perú	Legal Representative of Consorcio Leoncio Cárdenas Morán y Constructora RGH Contratistas Generales S.R.L.	Perú	2/9/2009	2/9/2012	Fraudulent Practices, Art. 5.02 (c)(iii) General Conditions Contract Agreement 1325/OC-PE
Diseño y Construccion en Ingenieria Civil y Agricola S.A.	Firm/Guatemala		Guatemala	1/26/2009	1/26/2014	Collusive Practices, Art. 5.02 (c)(iv) General Conditions Contract Agreement 1331/OC-GU
Luis Fernando Espino Montenegro	Individual/Guatemala	Legal Representative and Owner of Diseño y Construccion en Ingenieria Civil y Agricola S.A.	Guatemala	1/26/2009	1/26/2014	Collusive Practices, Art. 5.02 (c)(iv) General Conditions Contract Agreement 1331/OC-GU
Diseño de Ingenieria de Riego y Agua S.A.	Firm/Guatemala		Guatemala	1/26/2009	1/26/2014	Collusive Practices, Art. 5.2 (c)(iv) General Conditions Contract Agreement 1331/OC-GU
Victor Manuel Chavez	Individual/Guatemala	Legal Representative and Owner of Diseño de Ingenieria de Riego y Agua S.A.	Guatemala	1/26/2009	1/26/2014	Collusive Practices, Art. 5.2 (c)(iv) General Conditions Contract Agreement 1331/OC-GU
Agroservicios M&M	Firm/Guatemala		Guatemala	1/26/2009	1/26/2014	Collusive Practices, Art. 5.02 (c)(iv) General Conditions Contract Agreement 1331/OC-GU
Milagro Amparo Escobar Sandoval de Sandoval	Individual/Guatemala	Owner of Agroservicios M&M	Guatemala	1/26/2009	1/26/2014	Collusive Practices, Art. 5.02 (c)(iv) General Conditions Contract Agreement 1331/OC-GU
Consulfrutha S.A.	Firm/Guatemala		Guatemala	1/26/2009	1/26/2014	Collusive Practices, Art. 5.02 (c)(iv) General Conditions Contract Agreement 1331/OC-GU
Jorge Mario Cabrera Madrid	Individual/Guatemala	Owner and Manager of Consulfrutha S.A.	Guatemala	1/26/2009	1/26/2014	Collusive Practices, Art. 5.02 (c)(iv) General Conditions Contract Agreement 1331/OC-GU
Cesar Augusto Juarez Barreta	Individual/Guatemala	Legal Representative and Owner of Consulfrutha S.A.	Guatemala	1/26/2009	1/26/2014	Collusive Practices, Art. 5.02 (c)(iv) General Conditions Contract Agreement 1331/OC-GU
Agrosistemas B.S.	Firm/Guatemala		Guatemala	1/26/2009	1/26/2014	Collusive Practices, Art. 5.02 (c)(iv) General Conditions Contract Agreement 1331/OC-GU
Byron Leonel Sandoval Castañeda	Individual/Guatemala	Legal Representative and Owner of Agrosistemas B.S.	Guatemala	1/26/2009	1/26/2014	Collusive Practices, Art. 5.02 (c)(iv) General Conditions Contract Agreement 1331/OC-GU
Gabinete Tecnico, S.A. de C.V. (GATESA)	Firm/Honduras		Honduras	1/26/2009	1/26/2014	Fraudulent practices, Art. 5.02 (c)(iii) General Conditions Contract Agreement 1053/SF-HO
Juan Jacobo Káttan Káttan	Individual/Honduras	Partner of GATESA	Honduras	1/26/2009	1/26/2014	Fraudulent practices, Art. 5.02 (c)(iii) General Conditions Contract Agreement 1053/SF-HO
Osmar Danilo Castellanos Vásquez	Individual/Honduras	Partner of GATESA	Honduras	1/26/2009	1/26/2014	Fraudulent practices, Art. 5.02 (c)(iii) General Conditions Contract Agreement 1053/SF-HO
Joséfina Salazar Barrera	Individual/Honduras	Partner of GATESA	Honduras	1/26/2009	1/26/2014	Fraudulent practices, Art. 5.02 (c)(iii) General Conditions Contract Agreement 1053/SF-HO
Telma Iris David de Licona	Individual/Honduras	Legal representative, general manager and majority shareholder of GATESA	Honduras	1/26/2009	1/26/2014	Fraudulent practices, Art. 5.02 (c)(iii) General Conditions Contract Agreement 1053/SF-HO
Santa Berlioz Bendaña de Ocampo	Individual/Honduras	Project Chief of GATESA	Honduras	1/26/2009	1/26/2012	Fraudulent practices, Art. 5.02 (c)(iii) General Conditions Contract Agreement 1053/SF-HO
Claudia Díaz Durán de Rocco	Individual/Guatemala		Guatemala	1/16/2009	1/16/2012	Fraudulent Practices, Art. 5.02 (c)(iii) General Conditions Contract Agreement 1221/OC-GU
Carlos Olivella	Individual/Colombia		Colombia	7/16/2008	7/16/2013	Bribery Practices, Art. 6 (d)(i) General Conditions of Technical Cooperation Agreement ATN/ME-7978-CO
Patricio Galindo Vargas	Individual/Bolivia		Bolivia	7/16/2008	7/16/2013	Fraudulent Practices, Art. 5.02 (c)(iii) General Conditions Contract Agreement 995/SF-BO
Amparo Navia de Camacho	Individual/Bolivia		Bolivia	7/16/2008	7/16/2013	Fraudulent Practices, Art. 5.02 (c)(iii) General Conditions Contract Agreement 995/SF-BO
Juan Jose Chacon Bozo	Individual/Bolivia		Bolivia	7/16/2008	7/16/2013	Fraudulent Practices, Art. 5.02 (c)(iii) General Conditions Contract Agreement 995/SF-BO
Camara Agropecuaria de La Paz (CALP)	Firm/Bolivia		Bolivia	4/28/2008	4/28/2012	Fraudulent Practices, Art. 6 (d) (iii) General Conditions of Technical Cooperation Agreement ATN/MH-7005-BO
Juan Carlos Zamorano Rodriguez	Individual/Bolivia		Bolivia	4/28/2008	4/28/2012	Fraudulent Practices, Art. 6 (d) (iii) General Conditions of Technical Cooperation Agreement ATN/MH-7005-BO
Hernan Tito Velasquez	Individual/Bolivia		Bolivia	4/28/2008	4/28/2012	Fraudulent Practices, Art. 6 (d) (iii) General Conditions of Technical Cooperation Agreement ATN/MH-7005-BO
Ivan Aguirre Peña	Individual/Bolivia		Bolivia	4/28/2008	4/28/2012	Fraudulent Practices, Art. 6 (d) (iii) General Conditions of Technical Cooperation Agreement ATN/MH-7005-BO
Oscar Alberto Díaz	Individual/Argentina	Principal Technical Advisor of the Programa de Eficiencia y Transparencia en las Compras y Contrataciones del Estado	Honduras	2/20/2008	2/20/2018	Corruptive practices. Art 5.02 (c)(i) General Conditions Contract Agreement 1059/SF-HO
Ana Noemí Santamaría	Individual/Argentina	Legal representative of Swiss Purchasing Company S.A. (Swip.Co)	Honduras	2/20/2008	2/20/2018	Corruptive practices. Art 5.02 (c)(i) General Conditions Contract Agreement 1059/SF-HO
Luis A. Ledezma	Individual/Bolivia		Bolivia	9/27/2007	9/27/2012	Fraudulent and collusive practices, Art 5.02 (c)(iii)(iv) General Conditions Contract Agreement 1050/SF-BO
Santiago Romero	Individual/Bolivia		Bolivia	9/27/2007	9/27/2012	Fraudulent and collusive practices, Art 5.02 (c)(iii)(iv) General Conditions Contract Agreement 1050/SF-BO
Anibal Aldana Ortega	Individual/Bolivia	Manager of Empresa Constructora ALINCO SRL	Bolivia	9/27/2007	9/27/2012	Collusive practices, Art 5.02 (c)(iv) General Conditions Contract Agreement 1050/SF-BO
Renan Alfredo Rodriguez	Individual/Bolivia	Manager of Empresa Constructora del SUR CONSUR SRL	Bolivia	9/27/2007	9/27/2012	Collusive practices, Art 5.02 (c)(iv) General Conditions Contract Agreement 1050/SF-BO
Empresa Constructora ALINCO SRL	Firm/Bolivia		Bolivia	9/27/2007	9/27/2012	Collusive practices, Art 5.02 (c)(iv) General Conditions Contract Agreement 1050/SF-BO
Empresa Constructora del SUR CONSUR SRL	Firm/Bolivia		Bolivia	9/27/2007	9/27/2012	Collusive practices, Art 5.02 (c)(iv) General Conditions Contract Agreement 1050/SF-BO
Manuel Herce	Individual/Spain	Manager of Enginyeria i Gestió d’Infraestructures S.L. (EGI)	Honduras	9/13/2007	9/13/2017	Corrupt practices, Art 5.02 (c)(iii) General Conditions and Art 2.01 Annex B Contract Agreement 1106/SF-HO
Enginyeria i Gestió d’Infraestructures S.L. (EGI)	Firm/Spain		Honduras	9/13/2007	9/13/2017	Corrupt practices, Art 5.02 (c)(iii) General Conditions and Art 2.01 Annex B Contract Agreement 1106/SF-HO
Miguel Rojas Alba	Individual/Bolivia	General Manager of CIACONST Srl	Bolivia	5/18/2007	5/18/2012	Fraudulent and corrupt practices, Art 5.02(c) (iii) General Conditions and Art. 2.01 Annex B Contract Agreement 1075/SF-BO
CIACONST S.R.L.	Firm/Bolivia		Bolivia	5/18/2007	5/18/2012	Fraudulent Practice, Art 5.02(c)(iii) General Conditions and Art. 2.01 Annex B Contract Agreement 1006/SF-BO
Gabriel Mejía Valdivieso	Individual/Bolivia	General Coordinator of the Congreso Digital project	Bolivia	3/23/2007	Permanent	Fraudulent and Collusive Practices, Art 6 (d)(iii) and Art 6 (d)(iV) General Conditions of Technical Cooperation Agreement ATN/SF- 8904-BO
Dolores Conde Villegas	Individual/Bolivia	Legal Representative of Desarrollo en Sistemas y Computación DELCOM	Bolivia	3/23/2007	Permanent	Fraudulent and Collusive Practices, Art 6 (d)(iii) and Art 6 (d)(iV) General Conditions of Technical Cooperation Agreement ATN/SF- 8904-BO
Desarrollo en Sistemas y Computación DELCOM	Firm/Bolivia		Bolivia	3/23/2007	Permanent	Fraudulent and Collusive Practices, Art 6 (d)(iii) and Art 6 (d)(iV) General Conditions of Technical Cooperation Agreement ATN/SF- 8904-BO
Juan Batista	Individual/Panamá	Director and Member of Educación Técnica Especializada S.A. EDUTEC	Panamá	3/23/2007	Permanent	Fraudulent Practice, Art 5.02(c)(iii) General Conditions and Art. 2.01 Annex B Contract Agreement 1403/OC-PN
Mirna Murillo de Vergara	Individual/Panamá	Owner and Secretary of Educación Técnica Especializada S.A. EDUTEC	Panamá	3/23/2007	Permanent	Fraudulent Practice, Art 5.02(c)(iii) General Conditions and Art. 2.01 Annex B Contract Agreement 1403/OC-PN
Adán Acosta Sánchez	Individual/Panamá	Owner, Director and Treasurer of Educación Técnica Especializada S.A. EDUTEC	Panamá	3/23/2007	Permanent	Fraudulent Practice, Art 5.02(c)(iii) General Conditions and Art. 2.01 Annex B Contract Agreement 1403/OC-PN
Geneva Alonso	Individual/Panamá	Vice President and Director of Educación Técnica Especializada S.A. EDUTEC	Panamá	3/23/2007	Permanent	Fraudulent Practice, Art 5.02(c)(iii) General Conditions and Art. 2.01 Annex B Contract Agreement 1403/OC-PN
Siria Rodríguez de Batista	Individual/Panamá	President, Director and Legal Representative of Educación Técnica Especializada S.A. EDUTEC	Panamá	3/23/2007	Permanent	Fraudulent Practice, Art 5.02(c)(iii) General Conditions and Art. 2.01 Annex B Contract Agreement 1403/OC-PN
José Gonzalez	Individual/Panamá	Employee of Educación Técnica Especializada S.A. EDUTEC	Panamá	3/23/2007	Permanent	Fraudulent Practice, Art 5.02(c)(iii) General Conditions and Art. 2.01 Annex B Contract Agreement 1403/OC-PN
Benigno Tomás Rodríguez	Individual/Panamá	Employee of Educación Técnica Especializada S.A. EDUTEC	Panamá	3/23/2007	Permanent	Fraudulent Practice, Art 5.02(c)(iii) General Conditions and Art. 2.01 Annex B Contract Agreement 1403/OC-PN
Reynaldo Anel Córdoba	Individual/Panamá	General Coordinator and Legal Representative of Educación Técnica Especializada S.A. EDUTEC	Panamá	3/23/2007	Permanent	Fraudulent Practice, Art 5.02(c)(iii) General Conditions and Art. 2.01 Annex B Contract Agreement 1403/OC-PN
Educación Técnica Especializada S.A. EDUTEC	Firm/Panamá		Panamá	3/23/2007	Permanent	Fraudulent Practice, Art 5.02(c)(iii) General Conditions and Art. 2.01 Annex B Contract Agreement 1403/OC-PN

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