The World Bank Voluntary Disclosure Program (VDP): A Distributive Justice Critique

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The Voluntary Disclosure Program (VDP) is a new World Bank initiative designed to combat the illicit diversion of Bank funds. Under the VDP, contractors that confess corruption in connection with prior Bank projects, name their co-conspirators, and implement an internal compliance program are spared the penalties which would customarily attach to the disclosed misconduct. This Note argues that the VDP offends the fairness principle of distributive justice, which requires that inequalities resulting from any regulatory change be arranged to the benefit of the least advantaged. Specifically, the VDP threatens to exacerbate two present resource disparities.