How We Work : Compliance

Arne Hoel, The World Bank

CAO initiates audits in response to concerns regarding the social and environmental impacts of specific IFC or MIGA projects, or as requested by the World Bank Group President or senior management.

CAO Compliance

CAO Compliance assesses how IFC and MIGA assure themselves of environmental and social performance at the project-level. Investigations focus on IFC or MIGA - not the project sponsor - and examine compliance with relevant policies, standards, guidelines, procedures, and conditions. CAO compliance investigations are independent of, but complementary to, IFC/MIGA's internal assurance efforts.

How are compliance appraisals and investigations initiated?

Compliance investigations are triggered:

  • At the request of the President of the World Bank Group or senior management of IFC/MIGA

  • At the discretion of the CAO Vice-President

  • When a complaint is transferred from CAO Dispute Resolution where resolution of the issues is not possible

What is the process for compliance investigations?

First, CAO initiates an appraisal to determine whether a compliance investigation is merited.  The appraisal assesses whether there are substantive concerns regarding a project’s environmental or social performance.  In the event that the issues raised do not merit an investigation, CAO will close the case.

If an investigation is merited, CAO typically employs one or more independent experts to conduct the investigation. The investigation is based on a review of documents, interviews, and observation of project activities and outcomes. Verification of evidence is an important part of the process.

Monitoring and Reporting

In cases where IFC, MIGA, and/or project sponsors are in compliance, CAO will close the investigation with no further action.  In cases where IFC or MIGA is found to be out of compliance, CAO keeps the investigation open in monitoring until actions taken by IFC or MIGA assure CAO that the project is in compliance and the case can be closed.

See CAO's Operational Guidelines for more information on CAO's compliance process.

See Our Cases for all past and present compliance cases.

Compliance Peer Review 2016

As part of ongoing Monitoring and Evaluation (M&E) work, CAO commissioned a peer review of its compliance reports in 2016. The review, which was conducted by a former member of the Asian Development Bank's Compliance Review Panel, found CAO reports to be robust with evidence even-handedly set out and analyzed prior to reaching conclusions. The review also found there was solid justification for the decision to investigate in each of the cases that proceeded to the compliance investigation stage. The review makes recommendations in relation to structuring of reports and improving their readability. CAO expects to conduct regular peer reviews as part of its M&E work.


The report summary, as prepared by Dr. de Silva, is available below:

CAO Monitoring and Evaluation: FY17 Compliance Peer Review