CAO Releases Compliance Omnibus Monitoring Report, Q3 FY2025: Updates From Six Cases Across Africa and Latin America

In April 2025, CAO published its Compliance Omnibus Monitoring Report, Q3 FY2025, presenting updates from our monitoring of IFC’s response to compliance investigations in Chile, Egypt, Panama, South Africa, Togo, and Uganda.

This report presents outcomes from CAO’s monitoring of six cases across Latin America and Africa. Four cases—Chile: Alto Maipo-01 and -02, Panama: Transmission Line IV (PL IV-01), Egypt: Alexandria Development-02 and -03, and South Africa: Lonmin-02 —are being monitored under the 2021 CAO Policy. Two cases—Togo: Lomé Container Terminal (LCT-01 and -03), and Uganda: Bujagali Energy-04, -06, -07, and -08—are being monitored under the 2013 CAO Operational Guidelines.

CAO closed four cases:

• LCT-01 and -03 (Togo): Closed with Partly Unsatisfactory and Unsatisfactory ratings, on project-level performance.
• Bujagali Energy-04, -06, -07, and -08 (Uganda): Closed with mixed ratings: Satisfactory for supporting the livelihood of injured former workers, Unsatisfactory for unpaid wages to workers and lack of land compensation.
• Alexandria Development-02 and -03 (Egypt): Closed with a Satisfactory rating for systemic-level actions to train staff on retrenchment issues in projects.
• Lonmin-02 (South Africa): Closed with a Satisfactory rating on systemic-level actions to strengthen IFC’s internal controls over E&S Action Plans.

Two cases remain open as CAO continues to monitor IFC’s implementation of project-level and systemic-level commitments:

• Alto Maipo-01 and -02 (Chile): Monitoring remains open as verification of effective implementation of the Handbook on cumulative impact assessments, and the timely updates to project disclosure is still pending.
• PL IV-01 (Panama): Monitoring remains open on both project-level and systemic-level actions, with concerns about Indigenous Peoples' rights and delays in implementing IFC’s guidance for advisory services.

Monitoring is the final stage in CAO’s compliance process. For cases under the 2021 CAO Policy, CAO verifies the effective implementation of IFC/MIGA Management Action Plans (MAPs), which outline remedial actions to address the harm and non-compliance identified in CAO investigations. For cases that predate the policy, CAO monitors management’s actions until it is assured that non-compliance findings are being addressed.