The World Bank Group: Enforcement Trends and Insights from FY2025

The World Bank Group’s (WBG) Sanctions System Annual Report for FY2025 (the “Report”) highlights continued efforts to prevent and address fraud, corruption, collusion, coercion, and obstruction through a two-tier review system and stronger integrity compliance oversight. Covering the work of the Integrity Vice Presidency ("INT"), the Office of Suspension and Debarment ("OSD"), and the Sanctions Board from July 1, 2024 to June 30, 2025, the Report notes higher complaint volumes, steady sanctions, active settlements, and a heightened focus on rehabilitation under the revised Sanctioning Guidelines.

For companies bidding on or performing WBG financed projects, accurate bids, effective controls, and readiness to deliver on compliance commitments remain decisive, notably from a compliance perspective. WBG sanctions can also have downstream effects across impacted businesses because a debarment finding often functions as a practical integrity flag beyond MDB-financed work. This can trigger relevant representations in M&A transactions and in partner and lender due diligence and, in the United States in particular, may impact federal contractor assessments.

In summary, in FY25, INT received 4,268 complaints, opened 65 external investigations, and submitted 19 sanctions cases and 19 settlements to OSD. The Suspension and Debarment Officer (“SDO”) reviewed 20 cases and 19 settlements, issued 13 Notices of Sanctions Proceedings, and temporarily suspended 18 respondents. The Sanctions Board also issued two fully reasoned decisions. The Integrity Compliance Office (“ICO”) engaged with 101 sanctioned parties, released 18, and adjusted two sanctions based on compliance performance.

Key Takeaways from FY25 for Market Participants

1. Fraud remains the most common allegation at the first tier. In FY25, 64% of OSD cases and settlements included at least one fraud allegation. As a matter of course, companies should verify qualifications, experience claims, staffing commitments, and carefully review JV or subcontractor arrangements before submission of their bids.
2. Debarment with conditional release remains the default sanction. The revised Sanctioning Guidelines place greater weight on credible remediation and program effectiveness. Companies with risk-aligned controls and proof of implementation tend to achieve better outcomes and faster release.
3. Negotiated resolutions remain important. INT submitted 19 settlements in FY25 and OSD reviewed them for consistency with the Sanctioning Guidelines. Settlements often tailor debarment periods and compliance conditions, and can be more efficient than fully contested proceedings.
4. From a portfolio risk perspective, exposure often extends beyond the WBG. The Bank recognized 20 cross-debarments from other MDBs, and notified peers of 26 WBG debarments that may be recognized reciprocally.
5. Integrity compliance performance is decisive after sanctions. The ICO engaged with 101 sanctioned parties and released 18; one party that missed its release conditions had its sanction converted to debarment with conditional release. Paper programs without implementation can delay or reverse eligibility restoration.

The WBG Sanctions System: Structure and Process

The WBG’s system has three stages: investigation by INT, first-tier adjudication by OSD, and second-tier de novo review by the Sanctions Board, followed by ICO oversight of compliance conditions and release. It targets corruption, fraud, collusion, coercion, and obstruction in WBG financed operations to protect funds and encourage compliant participation. We explain these stages in further detail in our Legal Update, The World Bank Group: Enforcement Trends and Insight.

(1) Investigation: INT’s Activity and External Engagement

Compared to FY24, FY25 saw lower overall complaints but slightly higher investigative throughput: complaints fell from 4,984 to 4,268 (−716), while actionable complaints rose from 354 to 371 (+17); external investigations opened increased from 56 to 65 (+9) and completed decreased from 61 to 54 (−7). On sanctions pipeline activity, INT submissions increased: sanctions cases submitted rose from 13 to 19 (+6), and settlements submitted rose from 14 to 20 (+6). INT also pursued staff and vendor matters, and issued referrals and MOUs with national and regional authorities to strengthen cooperation and collaboration to facilitate information sharing.

(2) Adjudication: OSD Determinations and Sanctions Board Trends

From an adjudicative process perspective, OSD activity remained steady. In FY25 it reviewed 20 cases (including some from FY24) and 19 settlements, issued 13 Notices of Sanctions Proceedings, and temporarily suspended 16 firms and two individuals. Of 15 respondents whose appeal window closed, 12 did not appeal; uncontested matters generally resulted in the SDO’s recommended sanctions. OSD also returned several matters to INT for further development where evidence was insufficient.

In FY25, OSD’s misconduct mix remained broad, though fraud remained prevalent: notably, 64% of matters included fraud, 36% collusion, 33% obstruction, and 28% corruption. This profile aligns with procurement and project implementation risks. The Sanctions Board’s appellate activity remained modest, notably issuing two decisions after hearings in both cases. Across FY21–FY25, the appeal rate averaged 21%, with fraud common, and debarment with conditional release the most frequent outcome; the Board often applied shorter debarment periods than the SDO. From a multilateral perspective, cross-debarment continued to multiply impact: in FY25, OSD recognized 20 cross-debarments from other MDBs, and notified peers of 26 WBG debarments eligible for reciprocal enforcement.

(3) Integrity Compliance: Rehabilitation, Release, and Program Adequacy

ICO activity underscores the importance of remediation. The ICO sent 31 notices to newly sanctioned parties, engaged with 101 parties on compliance conditions, released 18 entities, and converted two sanctions based on performance. The revised Sanctioning Guidelines make rehabilitation a core policy goal, emphasizing tailored sanctions to promote credible reform. As of FY25, 39% of respondents sanctioned by the Sanctions Board since inception have achieved release and regained eligibility with the WBG and other MDBs.

Notably, 2025 saw a state-owned highway enterprise in East Asia and the Pacific released in June 2025 after more than a decade under sanction, following early and constructive engagement with the ICO and a comprehensive integrity compliance overhaul aligned with national standards, industry practice, and international guidance. This suggests that early and constructive engagement with the ICO can speed eligibility restoration.

The report notes the completion of the Integrity Compliance Knowledge Sharing Platform project, describing it as a significant achievement that delivers an online hub with free resources, training modules, guidance tools, interactive content, and a private‑sector networking hub to educate diverse users on integrity risks and best practices. The platform was developed with funding from the Korea–World Bank Partnership Facility and was piloted in 10 countries across Africa, Asia, and Europe, including fragile and conflict‑affected settings, to support practical uptake and capacity building.

(4) Trend Conclusions and Outlook

In FY25, enforcement remained strongly centred on fraud, especially in procurement‑phase representations and documentation, confirming that accuracy and verification at bid stage are the system’s primary pressure points. Cross debarment continues to extend consequences across MDB portfolios, elevating business continuity risk for globally active contractors and joint venture partners. US businesses will also recognise the broader “multiplier effect” concept: eligibility and integrity findings in one forum can have downstream consequences in other contracting and enforcement contexts, including False Claims Act scrutiny where applicable.

From a sanctions-policy perspective, practice continues to coalesce around debarment with conditional release, while negotiated resolutions provide a durable route to calibrated outcomes. Read together with the revised Sanctioning Guidelines, these trends reflect a sustained policy preference for remediation and rehabilitation alongside deterrence. From a compliance outcomes perspective, post sanction performance is decisive. ICO experience illustrates that demonstrable implementation, testing, and improvement accelerate release, while missed conditions can prolong or convert sanctions.

In short, the trend lines show that accuracy up front, credible remediation when issues arise, and disciplined follow through on integrity controls will best position participants for resilient access to WBG‑financed opportunities.

Mayer Brown is experienced in advising on all aspects of MDB integrity compliance and enforcement. For further details of our capabilities in this area, please visit our Multilateral Development Banks - Integrity Compliance and Enforcement page.