The World Bank Group steps up: Rising sanctions and a new era for integrity compliance

The WBG Sanction System’s Annual Report for Fiscal Year 2025 (FY25) shows an uptick in sanctions cases compared to previous years since 2020. Though enforcement remains below pre-pandemic levels, the annual report suggests that an increased number of complaints received by the Integrity Vice Presidency (INT) are gradually evolving into sanctions cases. In FY25, INT acted upon the most complaints since FY20.

This upward trend makes it even more important for entities receiving WBG funding to stay updated on anti-corruption compliance, even with the perception of reduced U.S. FCPA enforcement. And 2025 saw significant changes in the WBG’s compliance framework: the Integrity Compliance Office (ICO) updated its Integrity Compliance Guidelines (ICGs) for the first time in fifteen years, bringing fresh momentum and renewed focus to the fight against corruption.

In this alert, we reflect on WBG enforcement trends from FY25, outline the most important changes in the revised ICGs, and provide actionable insights to companies receiving WBG financing and compliance professionals at large. As the WBG doubles down on anti-corruption, companies receiving WBG financing should invest in robust integrity compliance programs that align with the updated ICGs to mitigate the risk of misconduct and sanction.

FY25 metrics: Enforcement creeps up

The WBG’s Sanction System’s Annual report for FY25 reflects a small but meaningful increase in enforcement activity. INT, which investigates complaints of suspicious activity, opened 65 new external investigations and completed 54 investigations from prior years. INT also submitted 19 sanction cases and 19 settlements to the Office of Suspension and Debarment (OSD), as well as one settlement to the International Finance Corporation’s (IFC’s) Evaluation Officer (EO). These numbers suggest that more complaints are developing into sanctions cases than in the recent past. FY21, FY24, and FY25 have seen a slightly higher number of settlements than sanctions cases indicating that respondents often prioritize certainty of outcome over litigation risk and cooperate with INT in exchange for negotiated outcomes.

From an adjudicative perspective, OSD reviewed 20 cases and 19 settlements, temporarily suspended 16 firms and two individuals, and sanctioned 12 respondents through uncontested determinations for fraudulent, corrupt, collusive, and obstructive practices. Fraud remains a key concern for the WBG. Consistent with prior years, fraudulent practices accounted for 64 percent of OSD cases.

Notably, there has been a significant rise in cases involving obstructive practices compared to pre-pandemic years. From FY18 to FY22, obstruction claims appeared in at most 11 percent of sanctions cases. In FY23, the percentage of obstruction claims began rising to 18 percent, then to 22 percent in FY22, and to 33 percent in FY25. This trend underscores the importance of effectively responding to an INT audit and inspection letter through experienced counsel, lest INT react adversely to what might be normal responses in a litigation or investigation context.

The Sanctions Board published two fully reasoned decisions resolving two contested sanctions cases involving three respondents, consistent with the metrics from FY24.

Compliance and remediation remain a critical piece of WBG’s Sanction System. In FY25, the ICO continued to support sanctioned parties in meeting their compliance obligations. During FY25, ICO sent 31 notices to newly sanctioned entities and engaged with 101 sanctioned parties to assess compliance progress and determine eligibility for sanction release. As a result, 18 entities were released from sanctions and two entities saw their sanctions converted – demonstrating the importance of working constructively with the ICO.

The reinvigorated Integrity Compliance Guidelines

The WBG further highlighted the importance of compliance to its integrity architecture in 2025 by overhauling its ICGs. The ICGs originally served as a benchmark for organizations seeking to meet WBG standards to be released from conditional sanctions, such as debarment with conditional release. Thanks to their supra-national nature and versatile design, though, the ICGs quickly expanded beyond that limited role and became one of the first global compliance program standards.

The ICGs and their implementation by the ICO were meant to account for the wide spectrum of companies receiving WBG funding, ranging from micro-companies in rural regions of developing countries to multinational companies with global operations. Since their initial adoption, developments in global compliance frameworks, as well as increased expectations from national and multilateral regulators, necessitated an update. The revised guidelines reflect harmonization with the Multilateral Development Bank (MDB) General Principles for Business Integrity Programmes and introduce expanded requirements for effective integrity compliance programs.

The revised guidelines aim to address emerging risks, clarify expectations, and codify ICO’s practice of over 15 years. We outline below key changes from the original version:

• Obstruction as misconduct – Alignment with ICO recommendations: The revised ICGs place a new focus on obstruction as a form of misconduct, bringing the guidelines in line with the WBG’s Anti-corruption Guidelines, which prohibit contractors from obstructing an investigation by INT. Integrity programs must treat obstruction as a serious compliance violation, subject to disciplinary measures.
• Integrity risk assessment – Broader approach: The guidelines continue to require a comprehensive integrity risk assessment process. The revisions invite companies to not only look internally but also to peer companies and the overall market where they operate to identify risk areas. Assessments may be conducted by external experts, but companies should understand that they are ultimately responsible for assessment outcomes. The revised guidelines also highlight technology-related risks.
• Management responsibility – Inclusion of middle management: The revised ICGs explicitly extended responsibility for integrity compliance to middle management, not just senior leadership. The revised guidelines underscore the importance of imbuing compliance responsibilities throughout all levels of management, reinforcing integrity standards and fostering a culture of integrity.
• Compliance resources – Adequacy emphasized: The revised guidelines stress the necessity of adequate resources for the compliance function, including personnel, technology, training, and access to data. Organizations are expected to demonstrate that their compliance programs are sufficiently staffed and supported to address both existing and emerging risks.
• Business development safeguards: New requirements target business development activities, mandating accurate representations in procurement processes, compliance with applicable laws, periodic reviews, and segregation of duties. Such controls help mitigate risks associated with sales and marketing. Controls over business development and participation in procurement processes is a particularly sensitive area for companies routinely participating in WBG-funded projects, where misstatements and omissions in bids may result in protracted audits, investigations, and sanctions proceedings.
• M&A integrity risk assessment: A dedicated section of the revised ICGs now addresses integrity risks in mergers and acquisitions. Prior to any transaction, organizations must thoroughly assess integrity risks, involve compliance teams early, and implement post-acquisition program integration, remediation, and monitoring.
• Emerging technology controls: The revised guidelines embrace emerging technologies, such as generative Artificial Intelligence (AI). At the same time, they also caution companies that they are ultimately responsible for the accuracy of AI-generated compliance advice. The guidelines also stress that AI tools should not actively learn from submitted queries, as this could precipitate confidentiality breaches. Finally, any AI-generated advice should remind users that AI-generated advice does not replace the compliance function. Users are still expected to report concerns through designated channels.
• Accessibility of compliance policies: The new guidelines counsel organizations to ensure compliance policies are readily available to all relevant personnel. They require companies to establish effective communication channels for propagating compliance communications and obtaining guidance on compliance matters.
• Strengthened anti-retaliation protections: The revised guidelines significantly strengthen anti-retaliation measures; protections now extend beyond whistleblowers to witnesses, investigators, and impacted business partners. The revised guidelines also expect organizations to implement formal anti-retaliation procedures and periodically measure their effectiveness. These measures extend to all forms of retaliation, including subtle or indirect actions, and are designed to foster a safe environment for reporting misconduct.
• Feedback and evaluation mechanisms: Organizations are now expected to implement feedback mechanisms to evaluate the effectiveness of compliance messaging and training. Regular assessment and adaptation of compliance programs are encouraged to ensure ongoing improvement, relevance, and engaging content.
• Expanded restrictions on Politically Exposed Persons (PEPs): The new ICGs broaden PEP-related requirements. Though the previous version of the guidelines focused on government officials, the revised guidelines call for controls on individuals who have been entrusted with prominent or political functions as well as their families and close known associates. In response to the revisions, organizations should develop and implement policies to identify, monitor, and restrict interactions with PEPs.
• Enhanced controls on charitable and political contributions: The guidelines call for risk assessment, due diligence, written agreements, and monitoring of charitable and political contributions. All contributions must be subject to rigorous review, documented in formal agreements with integrity-related undertakings, and managed in accordance with applicable laws and internal policies.

How companies should respond

Companies that receive financing from the WBG and other MDBs should take a critical look at their compliance policies and procedures and update them in accordance with the revised ICGs – especially as the WBG enforcement intensifies. But even for companies that do not receive WBG funds, the revised guidelines provide a critical window into global trends in anti-corruption compliance and may provide a valuable guide for compliance officers more broadly.

Authored by Peter Spivack, Shelita Stewart, Nikolaos Doukellis, and Varvara Novicichina.