Why a Joint MDB Sanctions Body Could Be a Smarter Path Forward
The idea of a global anti-corruption court has inspired conferences, academic debate, and institutional ambition. For integrity professionals, it holds clear appeal: a standing tribunal that could pierce political cover and prosecute transnational misconduct.
But the path from idea to institution is steep—and growing steeper.
Global Enforcement Isn’t Keeping Up
Despite growing calls for stronger global tools, enforcement trends are stagnating. Even well-established mechanisms like the FCPA are facing legal and political headwinds, while the ICC still faces limited buy-in and selective cooperation.
A global anti-corruption court would require unprecedented consensus across legal, political, and institutional lines. But:
Supranational oversight is often resisted by high-risk jurisdictions.
Treaty negotiations with 190+ countries pose enormous diplomatic hurdles.
Existing institutions struggle to enforce decisions across borders.
The political cost of real enforcement remains high in many contexts.
Meanwhile, corruption continues to destabilize countries, fuel conflict, and erode development gains. The need is urgent—but the perfect solution remains out of reach.
Maybe the Way Forward Isn’t Bigger—It’s Smarter
Rather than wait for global consensus, we should look for systems that already exist—and ask how they could evolve. One of the most functional and under-leveraged enforcement ecosystems already operating today is within the multilateral development banks (MDBs).
Over the last two decades, MDBs have created:
Shared definitions of sanctionable misconduct (fraud, corruption, collusion, etc.)
Internal investigative and sanctioning offices with global jurisdiction over their own projects
Agreed principles for treating corporate groups and evaluating compliance programs
A cross-debarment framework adopted by five major MDBs (World Bank, ADB, AfDB, IDB, EBRD)
This cross-debarment regime, in place since 2006, means that companies debarred by one MDB can be automatically barred by others—creating one of the only operational systems of mutual recognition in anti-corruption enforcement.
The Missing Piece: Coordinated Appeals
Despite this cooperation, MDBs still operate siloed appellate systems. Each bank maintains its own sanctions board or review panel, with separate procedures, jurisprudence, and resources.
That’s not just inefficient—it’s a missed opportunity.
Panels are often underused and costly to maintain.
Precedent is fragmented, even when cases involve multiple MDBs.
Smaller or newer MDBs lack capacity to run their own robust systems.
Creating a joint appellate mechanism could resolve these issues while reinforcing consistency and fairness across the board.
What Could a Joint MDB Sanctions Body Offer?
A shared appellate forum wouldn’t replace institutional autonomy or domestic jurisdiction. Instead, it could serve as a collaborative legal and procedural space that strengthens sanctions decisions without overstepping mandate.
Key advantages include:
Procedural consistency across cross-debarment cases
Lower costs through pooled resources and centralized secretariat support
Legal coherence, enabling a unified body of case law to guide enforcement
Scalability, allowing newer MDBs to opt in without building full systems from scratch
It could also serve as a testbed for future cooperation—a prototype for cross-institutional integrity governance.
What Would It Take to Make This Real?
A joint mechanism wouldn’t be easy to build. Each MDB has its own legal architecture and governance structure. Any shared system would require alignment not just among integrity units, but also across Executive Boards made up of diverse member states.
To move forward, MDBs would need to:
Align legal and procedural frameworks, while preserving core institutional mandates
Negotiate due process safeguards that ensure neutrality and legal robustness
Secure political buy-in to share enforcement authority—even when reputational stakes are high
Consider phased implementation or opt-in models to build consensus over time
Despite these hurdles, the opportunity remains compelling. Silence and fragmentation carry their own institutional risks.
Why This Matters Now
Integrity professionals know the costs of uncoordinated enforcement: inconsistent outcomes, loopholes in accountability, and weakened deterrence. As pressure grows to deliver on integrity, climate finance, and development impact, institutional credibility is on the line.
At STB Integrity, we’re not interested in waiting for perfect systems. We’re focused on high-impact, scalable reforms that can strengthen the field now. A joint MDB appellate body won’t solve every challenge—but it could anchor a more coherent, cost-effective, and trusted enforcement model.
The global anti-corruption court may remain aspirational. But MDBs already have the tools—and the track record—to go further.
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Hi, I'm Sârra-Tilila!
I help international organizations and NGOs strengthen their integrity frameworks through internal policy development, tailored trainings, misconduct investigations, and dispute resolution. With over a decade of legal and investigative experience, I’ve worked extensively in Africa and collaborated with global giants like the World Bank and the World Food Programme.
My work is driven by a deep passion for tackling fraud and corruption while promoting transparency and accountability in international development. If you’re looking for expert support to achieve your organization’s integrity goals, let’s connect!
© 2022 par Sârra-Tilila Bounfour