Disbursement of loans to PPP projects should only take place when there is evidence of expenditure by the Provider, with appropriate certification of this expenditure from the TA. When the EIB's loan is made in parallel with, or guaranteed by, a commercial bank syndicate, such controls are automatic under inter-creditor arrangements. However, in some of the projects reviewed where the EIB was not in this situation, these controls did not appear to be fully in place. There was a case where the EIB's loan has a state guarantee, the whole EUR 275 million of the initial EIB loan was disbursed into an offshore escrow account, with payments from this account controlled by the Promoter, the agent bank for the other lenders, and the EIB's guarantor. In other cases, "lump-sum" disbursements were used to match the EIB's funding arrangements. This begs the question of whether funding arrangements should drive the disbursement process.