World Bank: International Finance Corporation (IFC) & Multilateral Investment Guarantee Agency (MIGA) | Compliance Advisor Ombudsman (CAO)

  • Overview

    Private sector investments at the World Bank Group are managed by the International Finance Corporation (IFC) and the Multilateral Investment Guarantee Agency (MIGA).

    International Finance Corporation (IFC)

    Created In:1956

    Headquarters: Washington, D.C., United States

    Member Countries: 184

    Largest Shareholder: United States

    Mission: To promote sustainable private sector investment in developing countries, helping to reduce poverty and improve people’s lives.

    Multilateral Investment Guarantee Agency (MIGA)

    Created In: 1988

    Headquarters: Washington, D.C., United States

    Member Countries: 181

    Largest Shareholder: United States

    Mission: To promote foreign direct investment (FDI) into developing countries to help support economic growth, reduce poverty, and improve people’s lives.

    The Accountability Office: Compliance Advisor Ombudsman (CAO)

    Established in: 1999

    Functions: Compliance Review, Dispute Resolution, Advisory

    Visit the CAO’s website

    The IFC is the largest global development institution focused exclusively on the private sector in developing countries. The IFC has 184 member countries and works in more than a 100 developing countries to leverage private sector funding and encourage investment.

    The IFC’s Environmental and Social Performance Standards define IFC clients’ responsibilities for managing their environmental and social risks.

    The MIGA supports and encourages foreign direct investment. It has a set of social and environmental standards that investments must follow in order to obtain its guarantee. MIGA also has social environmental performance standards that apply to projects it covers.


    The Accountability Office

    The Compliance Advisor (CAO) is the accountability mechanism that receives complaints that stem from projects financed by the IFC or investments guaranteed by MIGA.

    The CAO has three functions:

    • The ombudsman (dispute resolution) function – The ombudsman is a dispute-resolution mechanism that seeks to resolve disputes in a mutually agreeable and flexible way without finding fault.  The goal of the ombudsman is to improve social and environmental outcomes on the ground.  Project-affected people may bring complaints to the ombudsman.
    • The compliance function – The CAO may oversee investigations of IFC and MIGA social and environmental performance to ensure that IFC and MIGA have complied with their policies, procedures, and guidelines.  Compliance investigations are undertaken only at the request of IFC or MIGA staff, at the CAO’s discretion, or in response to concerns raised in a complaint to the ombudsman.
    • The advisor function – The CAO gives advice to the president of the World Bank Group and staff of IFC and MIGA about particular projects or policies through the advisor function.

    Submit a complaint to the CAO if:

    • You are a person, group or organization (or their representative)
    •  You have been, or are likely to be affected by the social or environmental aspects of an IFC or MIGA project

    If the CAO determines that your complaint is eligible, it will conduct an assessment to determine which CAO role the parties are seeking. If dispute resolution is available, the CAO will facilitate a process designed to address the issues in the complaint with the goal of reaching a mutually agreeable solution. The dispute resolution process is voluntary and can only move forward if all parties agree. If complainants seek compliance, or if no agreement is reached through the dispute resolution process, the CAO will conduct an appraisal and may initiate a full compliance investigation to determine adherence to IFC or MIGA social and environmental policies. Compliance investigation reports are made public and the CAO monitors changes until the IFC and/or MIGA take steps to resolve noncompliance.

    For more information, see our brochure on the CAO (with SOMO), our Accountability Resource Guide, or visit the CAO’s website.

  • Our Advocacy

    Ensuring Responsiveness to Accountability Office Findings

    Accountability Counsel joins colleagues around the world in alarm over a trend at the World Bank Group. Increasingly, the bank’s management is refuting the findings of the bank’s independent accountability offices, the Inspection Panel and CAO, instead of developing plans to address confirmed violations of bank policy.

    In November 2013, Accountability Counsel and colleagues sent a letter to President Kim demanding an end to this pattern. In a June 2016 blog post, we called for the bank’s leadership to reject the false choice between rights and development. Our work is particularly important in a time where the bank is seeking to increase the private sector’s role in the development. As our recent Devex article outlines, if accountability is not strengthened at the bank, the bank’s efforts to “crowd in” the private sector will be a setup that harms the poor and vulnerable and widens the wealth and equity gap. We are also advocating for a change in incentives for bank staff, which should include incentives for robust due diligence, community consultation, and constructive engagement with the accountability offices’ complaint processes. We continue to engage bank leadership to ensure that the bank appropriately responds to its accountability offices, facilitates remedy for harmed communities, and implements lessons learned for future projects.


    Accountability for IFC Financial Intermediary Financing

    Accountability Counsel has also been actively working with partners to ensure that IFC financing of financial intermediaries – other banks and funds – does not harm vulnerable communities and that communities are able to effectively seek remedy for harms at the IFC’s accountability office. We have engaged the IFC’s leadership on FIs, which has resulted in commitments to improving the IFC’s environmental and social processes for its investments in the financial sector.


  • Past Advocacy
  • Documents

    Compliance Advisor Ombudsman (CAO) Guide by Accountability Counsel and SOMO

    Documents by Release Date

    November 2013Letter sent to World Bank President Jim Kim from Accountability Counsel and colleagues

    January 2013 CAO Operational Guidelines

    May 2012 – The CAO’s Draft Operational Guidelines

    September 2009 -The IFC’s Good Practice Note: Addressing Grievances from Project-Affected Communities