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This milestone is not only a leap forward for International Finance Corporation but also a hopeful sign for communities harmed by development projects around the world.
In a historic moment, the International Finance Corporation became the first development finance institution, or DFI, to adopt an explicit policy on remedy. On April 15, IFC published its Remedial Action Framework, formalizing a commitment to address environmental and social harms caused by IFC-supported investment projects.
This milestone is not only a leap forward for IFC but also a hopeful sign for communities harmed by development projects around the world. The Remedial Action Framework (RAF) is a cornerstone in a broader shift at a moment when the World Bank Group is planning to undertake a major overhaul of the environmental and social accountability systems on the public and private sides of the institution. The RAF sets the stage for a profound institution-wide commitment to avoid and remedy harm at the entire World Bank. Whether the grievance mechanisms and accountability systems of the institution change, or amendments to the environmental and social policies occur as part of this overhaul, the principles and drive for this cultural shift at the institution must now be rooted in the notion that remedy is possible at the World Bank.
As project-affected communities have illustrated through the years, harm is harm—no matter what type of investment may have led to it.
The IFC/Multilateral Investment Guarantee Agency (MIGA) framework is the result of years of advocacy, discussion, and perseverance by numerous stakeholders both outside and inside the institution, as recognized in the RAF itself. The strenuous efforts from civil society organizations (CSOs) and project-affected people from around the globe stemmed from firsthand experience of harm as well as technical recommendations and proposals to ensure that the remedy is centered on the rights and the needs of those who have been harmed.
The RAF is a fundamental part of an approach that will focus on remedy but will also make considerations about when and why to exit a project responsibly, as established in its Responsible Exit Approach issued in October 2024.
It is particularly meaningful that the RAF acknowledges that, like all development institutions, IFC and MIGA must play a role in the “remedial action ecosystem.” This recognition signals a full understanding of the core tenet of international law, namely that institutions should avoid infringing on the human rights of others and should address adverse human rights impacts when they have contributed to harm.
The RAF aims to provide a structured approach to address harm arising from the environmental and social (E&S) impacts of projects supported by IFC/MIGA. While the emphasis on the differentiated roles that IFC/MIGA and their clients play in providing remedy for harm remains, the support by IFC and MIGA for these remedial actions is a central part of the equation, focusing on:
The RAF will apply to all IFC-supported investment projects and all investment projects covered by MIGA political risk insurance guarantees. It makes distinctions for IFC/MIGA’s support for remedial actions, asserting they will vary depending on each case, stemming from factors such as the type of investment, proximity to harm, and other factors. Reaching an understanding of how these factors will be considered will require more detail than what is included presently in the RAF.
IFC/MIGA’s contribution to remedy will entail the use of influence and leverage to encourage clients to take remedial action, as well as providing support for enabling activities, such as fact-finding, technical assistance, and community development activities. Ultimately, the extent and effectiveness of these contributions will depend on the levels of engagement and participation from those seeking remedy.
While the RAF does contain references to institutional risks associated with providing direct funding for remedial actions by IFC/MIGA, it also acknowledges that the primary focus on enabling activities is meant to minimize these risks.
Notably, the RAF was approved on an interim basis, pointing to the importance of its three-year piloting phase to implement the approach. Practical application and enforcement of the RAF will certainly be the biggest challenge, but the inclusion of regular interactions with stakeholders, updates, and a final assessment to be conducted with the Compliance Advisor Ombudsman (CAO) to incorporate lessons learned to perfect the final policy is positive.
The RAF emphasizes sustainability frameworks and the value of strengthening prevention and preparedness and facilitating remedy through grievance mechanisms, echoing a long-standing demand from civil society that avoiding harm must be prioritized over managing its aftermath. It is admirable to finally have IFC recognize the crucial need to identify and manage E&S risks and potential impacts to avoid harm in the first place, but this too will require a change in operations and culture at IFC so that every aspect of IFC’s operations is seen through an environmental and social lens—a shift that aligns with a human rights-based approach.
Assessing a client’s preparedness and capacity to properly identify and mitigate environmental and social risks and to provide access to remedial actions in the event of harm is one of IFC/MIGA’s primary roles. If IFC/MIGA are committed to the complementary roles required for remedial action implementation, then this primary role becomes ever more salient and fixed to its new mandate.
The RAF should be praised. It has also created an opportunity to institute an approach to remedy within the entire World Bank Group at the perfect moment.
And as IFC begins the process of updating its Sustainability Framework, it is the perfect time to capture the principles and thrust of the Remedial Action Framework and Responsible Exit Approach in a manner that enhances broad adoption and integration of the approach to remedy at the entire institution.
Although the RAF does not mention the Responsible Exit Approach—including a reference to IFC/MIGA’s leverage over a “former client”—it nods to its relevance by recognizing the challenges faced when clients are not willing to address situations of harm. Planning with clients to ensure a responsible exit from all projects—and leveraging the role of IFC/MIGA in contributing to remedy through enabling activities—remains fundamental.
Based on the background provided in the RAF, one would assume that the framework is the result of the 2018 external review of the E&S accountability of IFC and MIGA, including the role and effectiveness of the CAO. Yet, civil society organizations that have been advocating for accountability and remedy for decades would quickly point to problematic projects such as Alto Maipo, Titan Cement, and Tata Tea, recalling the numerous communities who filed complaints proving the inadequacy of the system. For many of them, the ultimate catalyst for the turnaround would be the Tata Mundra case. This case—and the landmark Jam v. IFC litigation by Indian fisherfolk—highlighted the gaps in accountability when IFC dismissed the CAO’s findings and recommendations to bring the project into compliance and to provide remedy for communities.
Considering this history with the CAO, it is all the more notable that IFC/MIGA has embraced access to remedy as part of the holistic approach to remedial action within the RAF. They recognize the vital necessity of putting in place effective, reliable, and independent grievance mechanisms to address complaints raised by project-affected people when things go wrong.
IFC/MIGA emphasizes the client’s creation of an effective project-level grievance mechanism while maintaining the existence of IFC’s internal grievance mechanism—the Stakeholder Engagement and Response office—and the CAO. Together, these mechanisms make up the diverse cadre of options with varied levels of outcomes and results. By acknowledging the opportunity to capture lessons from the RAF’s initial implementation to inform updates to IFC/MIGA Sustainability Frameworks and the upcoming CAO Policy review, IFC/MIGA notably endorses raising the level of engagement and usefulness of these mechanisms.
For some time, CSOs and project-affected communities have been advocating for improvements to the CAO and grievance mechanisms at DFIs worldwide. Years of experience and long-standing collaboration led to the creation of the Good Policy PaperGuiding Practice from the Policies of Independent Accountability Mechanisms. These recommendations have been useful for numerous institutions seeking to improve their accountability frameworks with the ultimate goal of facilitating access to effective remedy.
As stated in the RAF, “IFC/MIGA as development institutions have a role to play in the context of the broader remedial action ecosystem and may contribute to remedial action in the following ways:
Even though the role of the client vis-à-vis IFC/MIGA is permanently interlinked, IFC/MIGA has approved an approach to remedy that still puts the client at the forefront of managing E&S risks and impacts, as well as funding and implementing remedial actions.
The initial perception of what was possible for a World Bank institution has evolved, noting IFC/MIGA’s commitment to contribute to Remedial Action as set forth in the RAF. While restating their role in using financial and contractual leverage to encourage clients to take remedial actions to address harm, IFC/MIGA will also provide support for enabling activities that will allow clients to provide solutions to project-affected people.
The scope of enabling activities may potentially allow for a broad range of actions by IFC/MIGA. While this will require practical experiences from the piloting phase to test and perfect the framework, initial considerations of enabling activities as presented in the RAF are promising as a minimum starting point:
Additionally, while IFC/MIGA expect that enabling activities will be the preferred mode of engagement in most cases where project-level remedial action is warranted, the RAF states that this does not prevent them from proposing other modalities for approval by the Board.
A major question and point of contention over these last years has been the cost of providing remedy. Here, the matter of differentiated roles has a direct bearing on the question of cost when IFC’s client is responsible for managing E&S risks and impacts. Something worth noting is the fact that private sector clients who joined IFC/MIGA consultations on the approach to remedial action were never opposed to remedy, but mainly concerned with how this could be done. They acknowledged the role of a project developer in remedying harms resulting from project construction, operations, etc. Their main question was always how to implement such a policy and how the costs would be allocated.
The RAF is clear about the costs for remedy, stating that under IFC’s Sustainability Framework, clients are responsible for managing E&S risks and impacts as well as funding and implementing remedial actions. While this would seem straightforward, the purpose of DFIs and the implementation of their mandates are at the core of an often nebulous division of roles. Considering this, the detailed description of IFC’s Sustainability Frameworks within the RAF comes into focus, as it is precisely the issue of a client’s ability to comply with IFC’s E&S policies and standards that makes IFC’s adjacent role more obvious and essential.
As we face environmental and climate crises globally, and financial institutions join in multiplying funds available to address the growing need for solutions, we can now point to the first remedial action framework and concrete driver for ways of addressing harm and providing remedy.
For instance, if IFC’s E&S due diligence at project appraisal is done properly, and if supervision and regular monitoring during project implementation are carried out entirely, then IFC can be sure that its client has managed E&S risks and impacts. As a result, the client adhered to IFC’s Performance Standards, applying the mitigation hierarchy correctly by taking all measures necessary to prepare for and avoid or minimize adverse impacts to the environment and preventing harm to people. However, when IFC fails to supervise and monitor its client properly, or when initial due diligence is lacking, or it neglects to notice a low-capacity client, then the risks are likely to materialize, causing harm.
If IFC realizes these errors, it may request corrective actions and changes to E&S Action Plans, so its client brings the project into compliance, yet this is not guaranteed. These are precisely the types of errors that have led affected communities to file complaints at the CAO, and the issues IFC has been grappling with for many years, ultimately leading to internal shifts and restructuring in E&S governance at the institution after assessing the entire accountability system.
Funding for contributions to remedial action by IFC will be obtained through the project’s funding structure, donor trust funds, IFC’s administrative budget, or operational risk capital. At the same time, MIGA’s contribution to remedial action activities is limited to available trust funds or existing budgetary resources.
Ultimately, the fact that IFC/MIGA has incorporated the possibility of using its own financial resources to contribute to remedial actions in the RAF, while still mentioning their concern for the risk of doing so, points to a change in perceptions that will ideally continue to shift the mode of thinking at the entire institution. Simply said, remedy should be seen as the goal from now on and something that should color all decisions at development finance institutions.
The RAF was approved by the Board of Directors of both IFC and the MIGA on April 3 on an interim basis for three years. Implementation of the RAF during the pilot phase will require IFC/MIGA’s regular engagement with stakeholders to receive input and share updates.
As an essential part of the initial six months of implementation, IFC and MIGA, in consultation with the CAO, will have to define and track key performance indicators related to efficiency and effectiveness to ensure proper monitoring of the interim approach. IFC/MIGA will also monitor implementation, providing the boards with briefings and annual monitoring reports.
A final assessment in consultation with the CAO will be carried out at the end of the three-year period. The final policy will incorporate lessons learned and proposed revisions for review by the boards.
The RAF should be praised. It has also created an opportunity to institute an approach to remedy within the entire World Bank Group at the perfect moment. As project-affected communities have illustrated through the years, harm is harm—no matter what type of investment may have led to it. As we face environmental and climate crises globally, and financial institutions join in multiplying funds available to address the growing need for solutions, we can now point to the first remedial action framework and concrete driver for ways of addressing harm and providing remedy.
Other institutions are now following suit. The IDB Group has indicated for several years that internal discussions on Remedy and Responsible Exit were already underway. Most recently, IDB Invest has prepared a draft approach to Responsible Exit based on the IFC/MIGA model and has been engaging with civil society and project-affected communities to receive feedback, while also moving on internal discussions for a remedy framework.
In the days following the approval of the IFC/MIGA Remedial Action Framework, CSOs had the opportunity to meet with IFC. The conversations had an immediate change in tone. This was a different conversation with other approaches for new projects, new contracts, thinking through how to make this framework a reality, with a sense of pride.
This was not lost on anyone. It revealed the legitimacy of having a framework and accompanying Responsible Exit Approach set to paper, as approved by the boards of these institutions. It showed its significance, its weight as a standard to follow, as a directive to take, and as a way forward for an institution that has finally recognized that development can sometimes have negative impacts, and that those impacts can lead to harm for communities. But now there is a way to address these harms and provide remedy, the commitment to do so has been set, and many are ready to make this happen, as challenging as it will undoubtedly be.
It is best to approach social justice the same way the world prepares for an eclipse—with foresight, community, and coordination.
Millions of people across the United States and parts of Canada and Mexico recently witnessed a total solar eclipse—a rare and breathtaking alignment of the Earth, moon, and sun. Scientists had predicted its precise timing and path years in advance, with detailed maps showing where the event would be most visible.
Across the U.S., communities prepared—gathering in fields, schools, and rooftops with protective glasses and cameras in hand. They trusted science. They trusted preparation. They showed up.
In the same week one year later, over 600,000 people across all 50 states signed up to protest against U.S. President Donald Trump and his ongoing threat to democracy for the Hands Off Protests in 1,300 locations. These protests were not spontaneous—they were planned, anticipated, and powerfully aligned. Total estimates for the day’s peaceful protests are 3 million people.
It is not always possible to predict the exact moment of breakthrough, but one can prepare for the shift through mutual aid, political education, youth leadership, and conflict transformation training.
If it is possible to chart the movement of celestial bodies with such precision, then it is also possible to chart the social conditions that produce change. Responses to the conditions that cause criminality, injustice, or violence can also be charted and faced.
A crime can unfold in seconds, but its consequences—especially in marginalized communities—can last a lifetime. The root conditions that set the stage—poverty, childhood trauma, environmental injustice, disinvestment in education, and systemic racism—are all in place and can be addressed.
Knowing the precursors of injustice, it is prudent not to sit still and wait for tragedy before taking action. It is best to approach social justice the same way the world prepares for an eclipse—with foresight, community, and coordination.
Research from the National Institutes of Health (NIH) confirms that adverse childhood experiences (ACEs)—like neglect, abuse, or household dysfunction—can have long-term impacts on health, behavior, and justice involvement. Communities with higher poverty rates have higher crime rates, not because of moral failure, but due to decades of disinvestment and inequality.
As someone who has spent decades working for criminal and social justice reform in communities and far beyond, I see that systems and practices can indeed seed meaningful social change.
The Theory of Change is a framework that maps how and why desired change is expected to happen in a particular context. It’s not magic. It’s modeling. And when used correctly, it helps communities anticipate outcomes and align resources toward justice.
Like eclipse chasers who travel to be in the “path of totality,” social justice organizers prepare to be where the change is coming. They build coalitions, train communities, and develop infrastructure so that when the time is right, they do not to miss the moment to act.
At this time in history when daily political efforts are aimed at reversing timeworn, proven paths to social justice, such as defunding financial assistance to federal programs, universities, associations, and individuals based on principles of diversity, equity, and inclusion, it is urgent to prepare and put into place ways to counter the effects.
This preparation involves policymakers, funders, nonprofits, communities, advocates, individuals, families, institutions, and faith-based organizations to work toward the goal of social change of equity, fairness, access, and justice.
You cannot stare directly at an eclipse without special tools. Similarly, you often can’t see the slow build of a movement until it’s in full swing. Yet humans can sense change—like animals do before an eclipse, like trees that darken and cool in response to a shadow overhead.
Similarly, social change is intangible yet deeply felt. It is not always possible to predict the exact moment of breakthrough, but one can prepare for the shift through mutual aid, political education, youth leadership, and conflict transformation training.
Preparation now is crucial. Facing funding cuts nationally to vital services, rollbacks of civil rights protections, and an increasing normalization of political violence, it is urgent to create needed structures that assess possibilities in order to anticipate and respond proactively.
Throughout history, research shows that Black women have sensed these shifts and led people and communities through them—not just during well-known moments—but in everyday resistance throughout the 20th and 21st centuries.
For example, Rosa Parks didn’t just refuse to give up her seat one time; she was a seasoned organizer and a supporter of the Student Nonviolent Coordinating Committee, or the SNCC Legacy Project. Shirley Chisholm wasn’t just the first Black woman to run for president—she helped reframe what political leadership looks like.
Barbara Jordan called out President Richard Nixon with such clarity it redefined accountability in American politics. Tennis icon Serena Williams crip-walked across a tennis court and reclaimed joy on a global stage. First Lady Michelle Obama wore sleeveless dresses and shattered expectations of what dignity and leadership looked like in a Black woman’s body.
A 2021 Texas A&M University study reports, “Black women, through their inclusive, community-based activist endeavors, continue to carve out fugitive spaces and counterpublics where counternarratives are actively generated to fight for a more equitable and inclusive democracy that serves all.”
As a Black woman, I see that Black women are the eclipse, the unexpected alignment. They have known through history how to bring light through the dark.
Social change can happen in quiet corners—in small towns, church basements, classrooms, or in the act of mentoring one young person. It doesn’t have to be a massive protest or a U.S. Supreme Court ruling. It can be both.
But when those moments do arrive—like the civil rights movement, the women’s movement, the LGBTQ+ rights movement—they are rarely surprises. They are the result of decades of work, layered with setbacks and strategy.
As Dr. Martin Luther King Jr. once said, “The arc of the moral universe is long, but it bends toward justice.” But that arc doesn’t bend on its own. It requires intention and action.
It is time not just to watch the changes happening, but to prepare and to make change, witnessing the outcomes together.
The arrest and detention of Mahmoud Khalil is part of the Trump administration’s larger project of creating and sustaining the illusion of endless enemies to distract from its oligarchic agenda.
The evening of the 8th of March, which coincides with the Holy month of Ramadan celebrated by almost 2 billion Muslims worldwide, took an expected turn for Mahmoud Khalil and his wife. Khalil just returned home from iftar—the evening meal Muslims eat to break their day-long fasting during Ramadan. His wife was eight months pregnant. The couple, perhaps, were preparing for the upcoming delivery of the baby and welcoming the new member of the family. Perhaps, they were getting ready to celebrate Eid al-Fitr, one of the two major religious festivals Muslims celebrate at the end of Ramadan.
What was likely not foreseen at all by this family was a raid, arrest, and detention by ICE. Mahmoud, a recent graduate of Columbia University and leading Palestinian solidarity organizer on campus, recently received his green card. A green card is the Permanent Resident Card that allows a person to live and work in the United States permanently. Mahmoud’s wife is a U.S. citizen. If all went well, Mahmoud could have applied for his U.S. citizenship after three to five years, subject to some terms and conditions. Because of being a legal permanent resident—the prior step to receiving U.S. citizenship through naturalization, ICE detention most likely was the last thing on Mahmoud’s mind.
I would argue that we are currently living in a state of exception. Since the Trump administration has assumed power, most of the welfare- and social justice-oriented laws and policies that were historically designed to protect and nurture our humans, environments, and the most vulnerable ones are being gradually replaced by extreme right-wing, hateful, and anti-all-kinds-of-minoritized-communities rules and regulations. To date, a total of 83 executive orders have been signed by President Donald J. Trump, and a significant portion of these orders are aimed at destroying environmental protections, abolishing social security, and cracking down against various marginalized and minoritized communities. If you are not a rich, white, Christian, U.S. citizen, cis-man, you are very likely to be impacted by a good number of these executive orders.
The goal is to remind us that we will be the next if we speak up and challenge oppressive systems.
A notable feature of most of these executive orders is that they appropriate the language of social justice. For example, the executive order titled “Defending Women from Gender Ideology Extremism and Restoring Biological Truth to the Federal Government” is nothing about defending women’s rights but everything about erasing trans- and nonbinary identities and experiences. If President Trump really cared about women’s rights, perhaps he would have allowed federal funding for elective abortion in government programs instead of reinstating the Hyde Amendment. Similarly, the executive order titled “Additional Measures to Combat Antisemitism” disproportionately targets Palestinian solidarity organizers in various institutions of higher education—specifically those who are not U.S. citizens.
Let’s not forget the 2017 white supremacist gathering in Charlottesville, Virginia, where marchers displayed swastikas and chanted slogans like “Jews will not replace us” and “blood and soil”—a Nazi ideological slogan. Trump was heavily criticized for adopting a “both-sides” narrative in response to the violent demonstrations, as he said, “But you also had people that were very fine people, on both sides.” A 2021 New Yorker article by David Remnick dives deeper into inquiring, “Is Donald Trump an Antisemite?” The article features a series of interviews that reveal that Trump was more pro-Israel than pro-Jewish. Some of the voices from the Israeli left criticized Trump for portraying American Jews as betrayers who betrayed Israel by voting for Democrats. The Guardian columnist Jonathan Freedland described Trump’s views towards Jews as, “...if American Jews don’t support what he says, they are ungrateful and he can question their loyalty. He sees Jews as foreign and supplicants who should be grateful to him.”
Against this background, when the Trump administration’s executive order to “combat Antisemitism” was enacted by the Department of State, the Department of Homeland Security (DHS), and U.S. Immigration and Customs Enforcement (ICE) by arresting and detaining Mahmoud Khalil, we should look beyond the formal accusation of antisemitism outlined by DHS on X: “Khalil led activities aligned to Hamas, a designated terrorist organization.” We must dive deeper into asking what exactly the series of xenophobic measures, which include but are not limited to travel bans, visa cancellations, crackdowns on immigrants and refugees, terminating the Spanish-language version of the White House website, and trade and diplomatic wars, along with cuts on government spending and reducing the size and scope of the federal government, aim to achieve.
The U.S. has long been transforming into an oligarchy, which has been alarmingly expedited under the leadership of Donald Trump and Elon Musk. An executive order has assigned the White House more power to monitor and vet independent federal regulation agencies, such as the Securities and Exchange Commission, the Federal Trade Commission, and the Federal Communications Commission, restricting their ability to regulate cryptocurrency trading or curb the monopoly of multinational tech giants like Meta or Amazon. Billionaire elites are engaged in a partnership with the state, where the state is primarily tasked with serving elite corporate interests. Professor Allison Stanger rightfully says, “When we grant tech leaders direct control over government functions, we’re not just streamlining bureaucracy—we’re fundamentally altering the relationship between private power and public governance.”
When the balance of power between private versus public sectors disappears, and the state is no longer aimed at serving the commoners, the state struggles to maintain its relevancy and seeks legitimacy from the common people. Noam Chomsky argues that one of the most effective ways to establish the state legitimacy is the creation of a culture of fear and the construction of endless enemies, which pits vulnerable communities against each other without drawing any attention to intersecting systems of oppression. Since the Trump administration is not going to serve anyone in this country except for its billionaire allies and rich-white-Christian-cis-male supporter base, it needs to give the rest of the people the impression that it is going to save them from some existentialist threats.
I would argue that the arrest and detention of Mahmoud Khalil is part of the Trump administration’s larger project of creating and sustaining the illusion of endless enemies, which include but are not limited to Arabs; Muslims; Palestinians; immigrants; refugees; Indigenous communities; people of color; women; the “undeserving” poor; and trans, queer, and nonbinary communities. Even though the Trump administration must be well aware of the fact that the oversimplistic conflation of all Palestinian solidarity organizers with “Hamas sympathizers” or the attempt to detain and deport noncitizen peaceful student protestors on the false ground of leading “activities aligned to Hamas” will face serious legal challenges in the court and pushback from progressive and social justice organizations, why does it continue to threaten Palestinian solidarity organizers?
I would say the goal is to leave a chilling effect. The goal is to remind us that we will be the next if we speak up and challenge oppressive systems. The goal is to emphasize that even securing a green card will not ensure that the constitutional right of freedom of speech or freedom of peaceful protest would extend to us. The goal is to push us to a state where we would start censoring ourselves in anticipation of being targeted long before the authoritarian state intervenes and starts penalizing us.
As the Trump administration attempts to restrict abortion and gender-affirming care and erase trans and nonbinary experiences in the name of protecting “life,” protecting “America’s children,” and protecting “family values,” Khalil was torn apart from his eight-month pregnant wife. The pregnant U.S. citizen wife was threatened with being arrested by ICE for trying to help her husband. The eighth month of pregnancy could feel debilitating, yet with a heavily pregnant body, Khalil’s wife has been forced to deal with the unbearable psychological and physical stress of spending hours communicating with lawyers and traveling between New York City and New Jersey trying to find the whereabouts of Khalil only to stay in the dark.
Will Khalil be able to be there with his wife on the day of Eid al-Fitr? Will he be able to be there by the side of his wife during the birth of their baby? If not, the United States does not really deserve to claim itself as “the land of the free.”