October 25, 2020

Volume X, Number 299


October 23, 2020

Subscribe to Latest Legal News and Analysis

The World Bank Should Create and Recommend Whistleblower Protections to Ensure Integrity in Governments’ Responses to the COVID-19 Epidemic

The World Bank has released a report and webinar on the unique opportunities for corruption that have arisen as nations respond to the COVID-19 epidemicAccording to the World Bank, such particularized corruption, which can already be seen in the United States and around the world, can be broken into four broad categories:

  • Corruption in the procurement of emergency supplies and services (including fraud);

  • Corruption in the delivery of emergency services and supplies (which may include diversion to political elites and those with affluence);

  • Corruption in the administration of the emergency response (such as filling emergency response jobs with unqualified but well-connected persons); and

  • Adoption and/or application of emergency powers to suit interest groups, or to use weakened government oversight for unrelated agendas.

To address such issues the World Bank included recommendations in its report to stop these particular types of corruptions such as: establishing explicit record keeping rules and require the recording of information relating to recipients of loans and/or grants; creating extraordinary auditing provisions, increasing the number or frequency of audits of emergency programs; and explicitly circumscribing the scope and duration of any emergency orders at the inception of those orders. Unfortunately, amongst this report’s recommendations, there is little reference to creating new whistleblower channels, encouraging whistleblowers, or ensuring the safety of whistleblowers.

The only relevant recommendation was establishing and advertising grievance redress mechanisms to enable individuals to raise complaints about the manner in which rules are enforced or if promised goods and services are not provided. Similarly, the webinar on COVID-19 related corruption focused only on educating the public about channels through which individuals in grant or loan receiving countries can report to the World Bank and ensuring that countries are transparent in their emergency actions so the public at large can spot fraud.

However, given the often powerful political or economic entities behind corruption, simply advertising that people can report corruption is not enough to encourage reporting. Policies must be in place to ensure the protection of COVID-19 whistleblowers, and the World Bank should consider encouraging nations to put such policies and mechanisms in place in its blog series on this topic or in any future report on this area of corruption.

Copyright Kohn, Kohn & Colapinto, LLP 2020. All Rights Reserved.National Law Review, Volume X, Number 206



About this Author


Maraya Best is an associate attorney with Kohn, Kohn & Colapinto. Ms. Best was the 2018 recipient of the highly prestigious and competitive Estelle S. Kohn Memorial Fellowship awarded by Northeastern University School of Law. She graduated from Northeastern University School of Law in May 2018 and holds a Bachelor of Arts degree in International Affairs and Hispanic Studies from Lewis & Clark College. Her background is in international human rights law, which she brings to KKC’s international anticorruption practice.