Zhong Lun Assists an ADB-sanctioned Chinese Infrastructure Company in Implementing its Compliance Program and Secures Reinstatement from ADB
Zhong Lun Assists an ADB-sanctioned Chinese Infrastructure Company in Implementing its Compliance Program and Secures Reinstatement from ADB
Zhong Lun has recently assisted a Chinese infrastructure company sanctioned by the Asian Development Bank (“ADB") in getting reinstatement.
The company is a domestic leading infrastructure contractor with significant international presence. Under China’s Belt and Road Initiative, the company's overseas business has expanded to Africa, Central Asia, Southeast Asia and other regions, as evidenced by its continuous rise in the ENR top 250 international contractors ranking.
Previously, due to its fraudulence in oversea bidding that violated the ADB’s standards, the ADB investigated the company and decided to debar it from participating in ADB-financed, administered or supported activities, and such sanction extended to parties related to the company or any entity in which the company has, or may in the future have, a principal beneficial interest or control. The reinstatement conditions required by the ADB include implementing a compliance program satisfying the ADB. The company then engaged Zhong Lun as its compliance counsel to assist it in implementing the compliance program.
Based on extensive experience in providing Chinese companies with services related to dealing with multilateral development bank investigations and implementing compliance programs and in view of the grounds for the sanction, the reinstatement conditions and the characteristics of the company, Zhong Lun tailored a compliance program that meets the requirements of the ADB after full communication with the ADB. During the less-than-two-year service to the client, Zhong Lun provided multiple compliance trainings, conducted four rounds of post-evaluation on the implementation of the compliance program and submitted an evaluation report to the ADB for each round of the evaluation. In that process, Zhong Lun communicated closely with the ADB and put forward work priorities and suggestions for improvement at each stage.Thanks to those all-out efforts, Zhong Lun has helped the company get the nod from the ADB to its reinstatement request.
This project demonstrates Zhong Lun’s outstanding capabilities in compliance in relation to multilateral development bank sanctions, featuring the firm’s forte of customizing compliance management programs that both meet the banks’ standards and fit clients’ own characteristics while striking a balance between efficiency and effect. Zhong Lun’s advantage of “global vision and global service" also plays an indispensable role. The firm’s work on this project has won high recognition from the company.
The partners in charge of this project are Changyu FU and Xiangming YI, and the team members include associates Xuan Jiang and Yangyuqian Meng.