Leveraging the World Bank's sanctions system for environmental and social governance: Institutional innovation at the intersection of integrity and sustainability

Abstract

This article argues that the World Bank Group's Sanctions System, originally designed to combat fraud and corruption in World Bank‐financed projects, can be strategically leveraged to strengthen environmental and social (‘E&S’) governance within and beyond World Bank‐financed projects. It contends that recent sustainable procurement reforms have created jurisdictional touchpoints through which the integrity‐focused Sanctions System may address E&S‐linked misconduct by contractors and other third parties during implementation of World Bank‐financed projects, complementing the World Bank's existing E&S oversight mechanisms. The article outlines the structure and mandate of the Sanctions System and then examines how its deterrent and rehabilitative functions can be extended to E&S‐related contexts. It concludes with forward‐looking recommendations for pilot implementation and institutional coordination, illustrating a possible form of institutional innovation that links integrity and sustainability governance frameworks.