Sanctions Board Insights | January 2026

[Sanctions Board]

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JANUARY • 2026

On behalf of the Sanctions Board Secretariat, I am excited to present this newsletter highlighting our progress and achievements during the second half of 2025. Throughout this period, our team has continued to champion integrity and accountability within the multilateral development community. We welcomed our new Chair and four new Sanctions Board Members, bringing fresh perspectives and energy. The Secretariat actively facilitated collaborative forums and knowledge-sharing initiatives, notably leading discussions on harmonization and cross-debarment at the Multilateral Development Banks Appellate Sanctions Bodies Conference in Beijing, China. We also contributed to innovative workshops and panel discussions, demystifying the appellate process and fostering open dialogue among our internal and external stakeholders.  In December, the Sanctions Board Secretariat, in collaboration with the Office of Suspension and Debarment and the Integrity Vice Presidency, published the World Bank Group (WBG) Sanctions System Annual Report. The Sanctions Board Secretariat and the Office of Suspension and Debarment also published the Data Companion. These publications provide valuable insights into the WBG’s commitment to ensuring its funds are used for their intended purposes.  These collective efforts have reinforced the essential role of the Sanctions Board and Secretariat in shaping effective sanctions enforcement while adhering to the principles of independence and fairness. Looking ahead to 2026, we remain dedicated to evolving our accountability mechanisms and championing integrity on a global scale. I hope you enjoy this version of Sanctions Board Insights. With warm regards, Jodi

*these figures are based on Sanctions Board Decisions in contested cases since 2007

In December, the Sanctions Board Secretariat welcomed a new member to the WBG Sanctions Board: Khaled Koubaa. You can learn more about our new member by reading the Updates on the World Bank Group Sanctions Board Members.

Khaled Koubaa, Sanctions Board Member

New Version of Sanctions Procedures for MIGA Cases

On December 18, 2025, the World Bank Group issued a new version of Sanctions Procedures for cases arising specifically in the context of MIGA projects. The MIGA Sanctions Procedures are part of a broader sanctions framework that includes other similar documents for potential sanctions proceedings in the context of projects financed by the Bank or IFC. This document replaces the previous version published in 2013 and incorporates a number of important updates, including rules on potentially extending sanctions to successors and processing requests to withhold certain evidence from accused parties.

WBG Sanctions System FY25 Annual Report and Data Companion

The Sanctions System Annual Report, released in December 2025 for fiscal year 2025 (“FY25”), was prepared in collaboration with the Integrity Vice Presidency, the Office of Suspension and Debarment, and the Sanctions Board Secretariat. The Report highlights key statistics and outcomes, introduces the newly appointed Sanctions Board members, and summarizes recent contested cases. It also demonstrates the Sanctions Board’s role in strengthening the impartiality and credibility of the World Bank Group’s Sanctions System and its ongoing efforts to combat fraud and corruption globally. The Report is available on the Sanctions Board website.

Along with the issuance of the Sanctions System Annual Report for FY25, the Sanctions Board Secretariat and the Office of Suspension and Debarment published the World Bank Group Sanctions System Data Companion. The Data Companion presents a variety of information and a summary of the two-tier Sanctions System's activities for FY25. Notable highlights include a list of parties sanctioned in FY25 involving debarment, and the industry sectors and regions of affected projects in cases considered by the Sanctions Board.

Quick Facts about the WBG Sanctions System

	The newly released video, “Quick Facts About the WBG Sanctions System, which explains how the Sanctions System fulfills this role, is now available in the following languages: - English - Arabic - Chinese - French - Portuguese - Spanish

Cross-Debarment and Beyond: Navigating the Evolving Landscape of Sanctions Enforcement

On November 3 and 4, 2025, the Asian Infrastructure Investment Bank (AIIB) hosted the Multilateral Development Banks Appellate Sanctions Bodies Conference in Beijing, China. The Sanctions Board Secretariat and Sanctions Board Chair, along with participants from other MDBs and International Financial Institutions, convened to discuss their experiences and learn from each other. By actively sharing best practices, the annual conference helps to shape the evolution of accountability mechanisms across the multilateral development landscape. Topics included harmonization among the MDB Sanctions Systems, principles of law, due process and integrity compliance. Notably, the Sanctions Board Secretariat facilitated an interactive moot court featuring Sanctions Board judges from the WBG, European Bank for Reconstruction and Development, Asian Development Bank and Asian Infrastructure Investment Bank. The Conference reaffirmed the essential role of collaboration and harmonization among MDBs in advancing effective sanctions enforcement.

Participants of the Multilateral Development Banks Appellate Sanctions Bodies Conference at AIIB in Beijing, China

Delivering Innovative Investigations Solutions

From November 5 to November 7, 2025, the Asian Infrastructure Investment Bank hosted the 25th Conference of International Investigators. Nearly 200 participants from more than 60 international organizations convened to exchange expertise, strengthen trust, and chart the next frontier of investigations work across international institutions. The Sanctions Board Secretariat, alongside EBRD and IDB, participated in a workshop moderated by the Integrity Vice Presidency to share lessons learned with the investigative community regarding decisions issued by the appellate bodies of sanctions systems. By explaining the appellate process, discussing case law, highlighting recurring challenges and lessons learned to avoid common pitfalls, the panel helped to demystify the appellate process and foster open dialogue and exchange.

Participants of the 25th Conference of International Investigators at AIIB in Beijing, China

Championing Integrity: 15 Years of Empowering the Private Sector for Sustainable Growth

On December 9, 2025, the World Bank Group’s Sanctions System celebrated International Anticorruption Day by hosting a series of engaging panels and discussions. The event honored 15 years of promoting integrity compliance as a cornerstone of sustainable private sector development. During the event, the World Bank Group’s Integrity Compliance Office launched the release of the World Bank Group Integrity Compliance Guidelines, which incorporate standards, principles and components commonly recognized by many institutions and entities as good governance, and anticorruption practices. The Sanctions Board Secretariat and the Office of Suspension and Debarment also jointly presented an overview of the evolution and impact of the Sanctions System over the past 15 years. Key highlights included a discussion on how sanctions can serve as a catalyst for sustainable growth and ethical business, with a particular emphasis on the role corporate integrity compliance programs play in determining an appropriate sanction and related conditions. Read more here.

International Administrative Law in Changing and Challenging Times

On November 19, 2025, the International Monetary Fund hosted its 30th Anniversary Conference. Judge Nassib G. Ziadé, President of the IMF Administrative Tribunal (IMFAT) and President of the United Nations Appeals Tribunal (UNAT), and who also serves as a World Bank Group Sanctions Board Member, led the Conference, providing welcoming remarks and serving as the keynote speaker. The Conference convened legal experts, judges, and practitioners from around the world to discuss the evolving landscape of international administrative law. The Conference featured a range of sessions addressing key topics such as the sources of international administrative law, recent developments and reforms, the jurisdiction of international administrative tribunals, the role of human rights, and the independence and selection of tribunal members. Jodi T. Glasow, Executive Secretary, the WBG Sanctions Board, joined Judge Pablo Sandonato de León, President of the Administrative Tribunal of the Organization of American States, on a panel to discuss the evolving role of jurisdiction of international administrative tribunals.

Judge Nassib G. Ziadé and Jodi T. Glasow

Global Suspension and Debarment Directory

Wencai Zhang, Managing Director and Chief Administrative Officer, World Bank Group, gave the keynote address at the November launch event of the 2025 Global Suspension & Debarment Directory - the Second Edition. Led by the World Bank’s Office of Suspension and Debarment, together with the Working Group, the Directory serves as an invaluable reference for policymakers, practitioners, and academics. It summarizes exclusion regimes in more than 36 jurisdictions across different continents and explores new areas of policy and practice, including monetary penalties, the role of compliance programs and remedial measures, and individual liability.

Louise Lecaros de Cossio, Counsel at the WBG Sanctions Board Secretariat

Louise Lecaros de Cossio	We are delighted to announce that Louise Lecaros de Cossio joined the Sanctions Board Secretariat as Counsel in September 2025. Louise brings extensive experience and outstanding qualifications to the role. You can learn more about her background here.

From Classroom to Global Impact: An Extern's Experience at SBS

Emmanuel Sogunle	The Sanctions Board Secretariat is fortunate to have Emmanuel Sogunle join as an Associate Extern from the Howard University School of Law Externship Program. You can learn more about his profile here.

Thank you for your interest in the work of the Sanctions Board and the Sanctions Board Secretariat. Learn more. As always, we welcome any questions, reactions, or suggestions for future editions. Please reach out to us via sanctio...@worldbank.org. Unsubscribe from this newsletter