Many governments use an administrative process, commonly known as “debarment” to mark problematic contractors as ineligible for future public contracts.1 While many acquisition professionals view the United States’ administrative—or discretionary—debarment system as a punitive process, it is, in fact, a protective one.2 However, the current U.S. administration has recently issued a robust whole-of-government strategy on countering corruption, which has increased the Government’s focus on anti-corruption enforcement.3