World Bank Group Updates International Integrity Compliance Guidelines
For the first time in 15 years, the World Bank Group (WBG) has updated their Integrity Compliance Guidelines.
The World Bank’s Integrity Compliance Office (IOC) first published the Guidelines in 2010 in order to advance integrity compliance in private sector development to ensure that funds awarded for sustainable development were not being misused. Although the World Bank promoted anti-corruption compliance decades earlier, the focus on integrity compliance for private companies has been the IOC’s main focus for the last 15 years and the Guidelines have played a pivotal role in shaping global standards for ethical business conduct.
The 2010 Guidelines set forth the standard for integrity compliance programs that sanctioned parties under WBG’s revised Sanctions Procedures must abide by in order to be released from debarment or conditional debarment. The 2010 guidelines outlined a risk-based framework for sanctioned parties that included core program elements involving prohibition of misconduct, responsibility in leadership, risk assessment and reviews, internal policies, policies for business partners, internal controls, training and communication, incentives, reporting misconduct, remediating misconduct, and collective action.
On November 24, the Guidelines were updated and significantly expand the scope and detail of the core pillars. The Guidelines now not only apply to sanctioned entities, but they may also be consulted when reviewing an entity’s compliance program prior to an imposition of a sanction, as well as outside the sanctions context.
New additions to the Guidelines include the following:
Explicit coverage of obstructive practices.
Defined terms (e.g., Politically Exposed Persons).
Program applicability to business partners, supply chains, and joint ventures.
Annualized risk assessments.
Enhanced use of technology.
Structured investigation and discipline protocols.
Mergers and acquisitions integration.
Business development controls.
Specific business partner contracting and monitoring requirements.
Core program elements remain the same but include greater specificity and modernized expectations.
Below is a general comparison of the major differences between the 2010 and 2025 versions of the Guidelines.
| Theme | Earlier Guidance | Revised Guidance | What Changed |
|---|---|---|---|
| Sanctionable practices | Fraud, corruption, collusion, coercion | Adds obstructive practices | Expanded scope of covered misconduct |
| Scope/reach | Sanctioned parties | Applies across WBG entities; usable pre‑sanction/outside sanctions; extends to affiliates, supply chains, joint ventures | Broader applicability and third‑party reach |
| Risk assessment | Periodic, update for changed circumstances | Ideally annual; across workforce, affiliates, transactions, partnerships, technologies; revise program after each review | Cadence and breadth clarified |
| Compliance function | Senior officer with autonomy/resources | Independence, stature, conflict of interest rules; data access for monitoring/testing | Stronger governance and capability |
| Decision‑making | Within internal policies principle | Elevated as a core principle; formal recording of risk‑informed decisions | More explicit governance expectation |
| Training/communication | Tailored training; publicize program | Impact assessment, feedback loops, multilingual access, senior communications | Outcome‑oriented enhancements |
| Advice/guidance | Provide guidance and urgent advice | Tech‑enabled advice (e.g., chatbots) with accuracy and confidentiality, reporting reminders, publicize mechanism for obtaining advice | Emphasis on accuracy, confidentiality, and availability |
| Reporting/whistleblowing | Duty to report; confidential channels; protections | Duty extends to external parties; anonymous options; employee awareness testing; anti‑retaliation | Wider obligation and system maturity |
| Investigations/remediation | Procedures to investigate and respond | Protocols for internal and external investigations; designated decision‑makers and remedies | Structured investigation governance |
| Employment controls | Vetting; periodic certification | Risk‑based ongoing vetting; integrity contract clauses; certification refined | Controls strengthened |
| Public Officials/Politically Exposed Persons (PEPs) | Restrictions on former public officials | Adds current officials and PEPs; protocols to avoid undue influence/appearance | Expanded population and safeguards |
| Gifts and Entertainment/ travel | Reasonable controls; travel addressed | Explicit limits, pre‑approvals, appearance of impropriety; limits on G&E | More granular controls |
| Political/donations | Lawful; disclosure required | Risk‑based diligence; management reviews/approvals | Documentation and oversight elevated |
| Facilitation payments | Prohibited | Prohibited; protocols for avoidance/reporting/duress training | More detailed requirements |
| Recordkeeping | Appropriate records | Auditable format; role assignments; access for audits/investigations | Audit‑ready documentation |
| Business development | Not addressed specifically | Controls for bids/proposals; segregation where appropriate | New control |
| M&A integration | Not addressed specifically | Post‑deal risk assessment and program integration; right to exit | New control |
| Business partners | Risk‑based diligence; reciprocal commitments; documentation; remuneration; monitoring; termination rights | Detailed contract terms (audit rights, conflict disclosure), ongoing risk‑based monitoring, payment controls | Greater specificity and enforceability |
| Internal controls/audit | Financial and organizational controls; independent audits | Regular internal/external audits and testing; act on findings | Testing and remediation expectations |
| Incentives/discipline | Positive incentives; disciplinary measures | Incentives for all employee levels; encouragement for business partners; discipline integrated with remediation | Wider coverage and integration |
The WBG is an international development organization with 189 member countries. It is made up of five interconnected international organizations that provide financing, policy advice, and technical assistance to developing countries.
The five organizations include:
- The International Bank for Reconstruction and Development.
- The International Development Association.
- The International Finance Corporation.
- The Multilateral Investment Guarantee Agency.
- The International Centre for Settlement of Investment Disputes.
Our team at ArentFox Schiff has extensive experience serving as independent anti-corruption compliance monitors advising multinational corporations pursuant to WBG Negotiated Resolution Agreements. Contact AFS for more information on the impact of the updated Guidelines and for assistance with anti-bribery and anti-corruption compliance policies.
