Documentation · Risks
Debarment and procurement fraud
Debarment bars a supplier from public contracts after fraud, corruption, bribery or other serious misconduct. Governments and multilateral lenders each keep their own lists. This guide explains the Canadian Integrity Regime, the US federal exclusions, the World Bank and other multilateral debarment lists, the UK debarment list and the EU exclusion system, and shows how to screen suppliers, subcontractors and owners against them.
Sources read 2026-10-10. Citations appear in square brackets and are listed under Sources.
What the risk is
Public buyers and development lenders purchase goods and services from private suppliers. When a supplier commits fraud, corruption or another serious integrity breach in a procurement, the buyer can stop that supplier from winning future work for a set period. This is debarment, and it is usually recorded on a published list.
In Canada, the Registrar of Ineligibility and Suspension can declare a supplier ineligible, or suspend it, from entering contracts or real property agreements with the Government of Canada [1][3]. In the United States, agencies may debar a contractor after a conviction for fraud or another criminal offence connected with a public contract, or for bribery, embezzlement or making false statements, among other causes [5].
The risk is not limited to the named company. Listings can reach affiliates, successors and connected persons. A buyer that contracts with a listed firm, or with a listed subcontractor, can inherit the problem [3][7][9].
How it shows up
These are the warning signs that a supplier may be listed, or may be a successor or affiliate of a listed supplier. They are prompts for review, not findings.
- A new name for an ineligible firm. The World Bank list records whether an entry is a controlled affiliate, a controlling affiliate, or a successor or assign of a sanctioned entity [7]. Treat a renamed company at the same address, with the same owners, as a possible match.
- Influence from a listed entity. Canada's policy addresses affiliates that were directed, influenced or authorized to act by a listed supplier [3].
- Corruption or collusion grounds. World Bank entries show grounds such as corrupt and collusive practices and fraudulent practices [7]. Any match in these categories needs a closer look.
- Conditional or settled outcomes. Some entries carry conditional non-debarment or a settlement agreement with integrity compliance conditions [7]. The firm is not cleared while those conditions run.
- Misconduct in other tenders. The UK treats acting improperly in other procurements as a discretionary ground for exclusion [9].
- Failure to cooperate with an investigation. In the UK, failure to cooperate with an investigation can itself lead to debarment [9].
- Shell companies. The EU exclusion grounds include entities created to circumvent fiscal, social or other legal obligations, including shell companies [8].
- Offences outside the buyer's own jurisdiction. Canada's policy treats similar provincial and foreign offences as grounds for ineligibility [3].
What regulators expect
Canada
The Office of Supplier Integrity and Compliance administers the Ineligibility and Suspension Policy, which sets out how and when a supplier may be suspended or declared ineligible from doing business with the Government of Canada [2]. The policy took effect on May 31, 2024 [3].
- An ineligibility period can run up to 10 years from delivery of the notice of ineligibility [3, s. 6.3].
- The Registrar may impose a provisional suspension of up to 90 days where a supplier poses an immediate and significant risk [3, s. 7.1.2].
- The Registrar may enter into an administrative agreement with a supplier, including as an alternative to termination of a contract [3, s. 6.5.4 and s. 10].
- The policy also refers to subsection 750(3) of the Criminal Code. A supplier that has no capacity to contract with Canada under that provision is not eligible for federal contracts [3, s. 9.1].
- The policy's suspension and ineligibility lists show the status, start date and end date for each supplier [1].
- Prime contractors can use the public list to confirm that subcontractors are eligible and to hold them to the same terms [1]. If the Registrar informs a buyer that a contractor is ineligible or suspended, the buyer must contact PSPC [11].
Canada's anti-bribery law also applies to Canadian businesses abroad. Under the Corruption of Foreign Public Officials Act, giving or offering a benefit to a foreign public official to obtain or retain a business advantage is an indictable offence, punishable by up to 14 years in prison. Keeping off-book accounts or false records to hide that bribery is a separate offence [4, s. 3 and s. 4].
Canadian reporting entities under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act are supervised by FINTRAC for their anti-money laundering and anti-terrorist financing duties [10]. A debarment list is a procurement list, not a FINTRAC list, so a listing is a due diligence input for a business rather than a reporting trigger in its own right.
United States
The Federal Acquisition Regulation, Subpart 9.4, sets out debarment, suspension and ineligibility. It lists the causes for debarment and the agencies' listing of contractors [5]. The public SAM.gov exclusions extract is published as downloadable files [6].
United Kingdom
Under the Procurement Act 2023, a Minister of the Crown may place a supplier on a published debarment list. Every contracting authority must check the list in each procurement [9, paras 2, 6 and 15]. Where a supplier is listed on a mandatory ground, the authority must not award it a public contract. Where the ground is discretionary, the authority may proceed only after careful review and an audit trail [9, paras 16 and 17]. Listings usually run for up to 5 years [9, para 31]. A supplier has 8 working days to seek interim relief after notice of a decision, and 30 days to appeal [9, paras 7, 9 and 38].
European Union
The Early Detection and Exclusion System (EDES) operates under the EU Financial Regulation (Regulation (EU, Euratom) 2018/1046). It covers all contracts, grant agreements and financial instruments financed from the EU budget. The grounds for exclusion in Article 138(1) include fraud and corruption, and the Commission publishes the most serious cases [8].
Multilateral development banks
The World Bank's list shows firms and individuals that are ineligible for World Bank-financed contracts for the periods stated [7]. Under a 2010 agreement, the World Bank, Asian Development Bank, European Bank for Reconstruction and Development, Inter-American Development Bank and African Development Bank enforce each other's debarments, effective July 1, 2011 [7]. The World Bank also publishes other sanctions, such as letters of reprimand and conditional non-debarment [7]. The Financial Action Task Force has published a reference guide and information note on combating corruption [12]. We read this from a summary only; the full note was not retrieved.
How to screen with Crown Intelligence
Screen suppliers, subcontractors, owners and directors against the registers below. A match is a lead to verify against the official list, using the record's status, dates, grounds and address. The rows are read from the Crown Intelligence source API when this page loads.
| Register | Rows (live) | Last loaded |
|---|---|---|
| Government of Canada, PSPC: ineligible and suspended suppliers [1] | Loading | - |
| US federal exclusions in SAM.gov [5][6] | Loading | - |
| Asian Development Bank debarment [7] | Loading | - |
| African Development Bank debarment [7] | Loading | - |
| European Bank for Reconstruction and Development debarment [7] | Loading | - |
| EU excluded and penalised financial operators [8] | Loading | - |
Not yet in the register catalogue, as of the bulk release dated 2026-10-04: the World Bank debarment list and the UK debarment list. Check the official pages before you rely on either [7][9].
Crown's debarment and enforcement collection holds the full set of debarment-type and enforcement registers. Current records and source counts come from the public bulk index: loading.
- Debarment and enforcement collection
- Search the debarment registers
- All debarment registers in the catalogue
- Canadian PSPC registers and US SAM registers
- Bulk metadata for every collection
Practical checklist
- Screen the supplier, its owners and directors, and each intended subcontractor against the registers that apply to the buyer [1][5][7][9].
- Check former names, affiliates and successors, because listings can reach them [3][7].
- Record each register, its date, the matched record's status, dates and grounds, and the decision made [9].
- Treat a conditional, settled or administrative outcome as an open condition, not a clearance [3][7].
- Re-screen before award, before any subcontractor change, and when a list changes [9].
- Include a contract clause requiring the supplier to tell you if it becomes ineligible or suspended [9].
- Escalate every match to compliance for a documented decision before any award or payment [9].
Frequently asked questions
Does a listing bar a supplier from every contract?
No. The reach depends on the list. Canada's ineligibility applies to contracts and real property agreements with the Government of Canada [3]. In the UK, a mandatory ground bars an award, while a discretionary ground leaves room for a reasoned decision [9]. World Bank listings apply to World Bank-financed contracts [7].
How long does a listing last?
In Canada, an ineligibility period can run up to 10 years [3]. In the UK, a listing usually runs for up to 5 years [9]. World Bank entries state their own periods [7]. Check the end date on each record before you act [1].
Is a name match enough to act?
No. Confirm the match against the address, dates and grounds on the official record. The World Bank notes that name searches can return close but different names [7].
Do we need to screen subcontractors?
Yes. Canada's list is written for prime contractors who need to confirm subcontractor eligibility [1]. The UK requires authorities to check associated persons and intended subcontractors [9].
Do provincial and foreign offences count?
They can. Canada's policy defines similar provincial and foreign offences as grounds for suspension or ineligibility [3].
Can Crown's records replace the official list?
No. Each Crown record is credited to its publisher and dated. Confirm it at the official source before you act on it.
Sources
- Public Services and Procurement Canada, "Ineligible and suspended suppliers under the Ineligibility and Suspension Policy", canada.ca. Page dated 2026-09-03. Read 2026-10-10.
- Public Services and Procurement Canada, "Office of Supplier Integrity and Compliance (OSIC)", canada.ca. Page dated 2025-12-12. Read 2026-10-10.
- Public Services and Procurement Canada, "Ineligibility and Suspension Policy", effective 2024-05-31, canada.ca. Read 2026-10-10.
- Government of Canada, Corruption of Foreign Public Officials Act (S.C. 1998, c. 34), laws-lois.justice.gc.ca. Current to 2026-09-21. Read 2026-10-10.
- Acquisition.gov, "Subpart 9.4 - Debarment, Suspension, and Ineligibility", FAR FAC 2026-01, effective 2026-03-13, acquisition.gov. Read 2026-10-10.
- General Services Administration, SAM.gov, public exclusions search, sam.gov. Read 2026-10-10.
- World Bank, "Listing of Ineligible Firms and Individuals", worldbank.org. The page states the list updates every 3 hours. Read 2026-10-10.
- European Commission, "Early Detection and Exclusion System (EDES)", commission.europa.eu. Milestone item dated 2026-06-18. Read 2026-10-10.
- Cabinet Office, "Guidance: Debarment (HTML)", Procurement Act 2023 guidance, gov.uk. Updated 2026-08-17. Read 2026-10-10.
- FINTRAC, "Financial Transactions and Reports Analysis Centre of Canada", fintrac-canafe.canada.ca. Page modified 2026-06-03. Read 2026-10-10.
- CanadaBuys, "Integrity provisions", canadabuys.canada.ca. Read 2026-10-10.
- Financial Action Task Force, "Corruption: Reference guide and information note", fatf-gafi.org. Read 2026-10-10 from the search summary only; the full PDF was not retrieved.
Last updated 2026-10-10