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.

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Publication Details

Journal
Review of European Comparative & International Environmental Law
Published
2026-07-01
DOI
https://doi.org/10.1111/reel.70080
Primary Topic
Economic Sanctions and International Relations
Type
article
Field-Weighted Citation Impact
0.00
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article

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

Chang Liu
Review of European Comparative & International Environmental Law
Economic Sanctions and International Relations
article

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

Chang Liu
article en

Abstract

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.

Review of European Comparative & International Environmental Law
World Bank Group (US)
Peace, Justice and strong institutions
Openalex Percentile: Top 3%
Economic Sanctions and International Relations
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Leveraging the World Bank's sanctions system for environmental and social governance: Institutional innovation at the intersection of integrity and sustainability — Chang Liu · Review of European Comparative & International Environmental Law (2026) | TGRS Research Map | TGRS