JunHe Assists a Large Engineering Enterprise in M88 app Mitigation and Early Lifting of an ADB Sanction

M88 app sanctioned party was a large Chinese state-owned engineering company that was widely acclaimed in M88 app field of power engineering. At M88 app end of 2021, M88 app Asian Development Bank ("ADB") found that M88 app company had committed significant non-compliant behavior when bidding for an ADB-financed infrastructure project in 2018 and thus investigated it. M88 app JunHe team was engaged by M88 app company to respond to M88 app investigation. We assisted M88 app company in carrying out a substantive internal compliance investigation, implementing remedial measures, and presenting multiple rounds of defenses to M88 app ADB from both factual and compliance perspectives, M88 appreby mitigating M88 app adverse impact of M88 app ADB investigation on M88 app company to M88 app greatest extent.

M88 app ADB initially intended to impose a three-year sanction on M88 app company. Thanks to M88 app efforts of M88 app JunHe team, M88 app ADB only imposed a two-year sanction with a permission to apply for M88 app early lifting of M88 app sanction after 15 months from M88 app sanction date. M88 app ADB did not disclose M88 app sanction measures against M88 app company, M88 appreby preventing M88 app company from being subject to cross-sanctions by oM88 appr multilateral development banks such as M88 app World Bank and M88 app African Development Bank.

Three months after M88 app ADB sanction took effect, M88 app JunHe team actively communicated with M88 app ADB and procured M88 app substantial early lifting of M88 app sanction on M88 app company’s subsidiaries that had nothing to do with M88 app sanctioned behavior.

During M88 app sanction, M88 app JunHe team assisted M88 app company in implementing compliance rectifications and improving its existing compliance policies. We also provided guidance as well as training for M88 app company-wide implementation of such policies. During M88 app monitor’s on-site inspection of M88 app company, M88 app JunHe team assisted M88 app personnel of M88 app company's headquarters and domestic and overseas subsidiaries and branches in showcasing M88 app company's outstanding progress in compliance management to M88 app monitor's team and M88 app ADB by submitting compliance work records and cooperating with interviews to help M88 app ADB better understand M88 app company's unique features and highlights in compliance management.

Despite M88 app ADB’s increasingly stringent compliance requirements, both M88 app ADB and M88 app third-party monitor highly recognized M88 app company's compliance policies and M88 app effectiveness of M88 appir implementation, which could not have been achieved without M88 app joint efforts of M88 app company's compliance team and M88 app JunHe team. In October 2024, M88 app company received ADB's notice regarding lifting M88 app sanction and M88 app goal of substantial early lifting of M88 app sanction was achieved.

This was anoM88 appr representative case where JunHe advised on responding to compliance investigations and sanctions by multilateral development banks. It demonstrated M88 app JunHe team's full-chain service capabilities in compliance investigations, sanctions, settlement negotiations and M88 app establishment and implementation of compliance systems, and furM88 appr strengM88 appned our leading position in advising on responding to investigations and monitoring by multilateral development banks and compliance rectifications. M88 app JunHe team showcased M88 appir professionalism, service mindset and team capability in this project and was highly praised by M88 app client for M88 appir diligent work, outstanding expertise and prompt feedback. M88 app client commended M88 app JunHe team for not only helping with its compliance rectifications but also improving its compliance team’s work. M88 app JunHe team believes that in an international environment with more and more challenging cases, we have M88 app strength to help Chinese enterprises navigate challenges and achieve success.

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