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Bretton Woods Observer Spring 2022
A quarterly critical review of developments at the World Bank and IMF

Published by BRETTON WOODS PROJECT
Working with NGOs and researchers to monitor the World Bank and IMF

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1. The IMF gender strategy: Will it lead to real change for women’s
rights?
2. The Bretton Woods Project welcomes new gender project staff
3. New IMF Resilience and Sustainability Trust (RST) – how to make it
work for the Global South
4. IMF capital control review: A missed opportunity to support a just
recovery and stability
5. World Bank’s re-labelled Business Enabling Environment Project
does little to address substantial flaws of Doing Business Report
6. World Bank announces support for CCUS in Nigeria despite
criticisms it reinforces fossil fuel dependence
7. IMF programme in Pakistan undermines renewable energy roll-out
8. Calls for Ukraine debt relief grow as IMF and World Bank provide
fresh loans amidst crisis
9. Civil society hails IFC’s divestment from for-profit education
provider Bridge International Academies
10. Ineffective G20 Debt Service Suspension Initiative ends as world
faces worst debt crisis in decades
11. Argentine civil society denounces new IMF agreement as
illegitimate
12. Report implicates IFC investments in human rights abuses of
Uyghur and other minorities in China
13. Civil society campaign urges IMF to stop using punitive
surcharges

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GENDER/analysis

The IMF gender strategy: Will it lead to real change for women’s
rights?

SUMMARY
- New IMF gender strategy outlines vision to mainstream gender across
lending, surveillance and technical assistance
- CSO statement calls for deeper analysis of the effects of Fund-
endorsed policies on women’s rights and a commitment to pursue
alternatives

Civil society and UN experts insist on urgent move away from gender-
blind fiscal consolidation as austerity wave looms
The socio-economic fallout from the Covid-19 pandemic has reversed
women’s rights gains by several decades, as reported by the UN, civil
society and media, while the World Economic Forum stated that
“another generation of women will have to wait for gender parity” as
closing the global gender gap has moved another 35 years away.
Meanwhile, a new wave of IMF-supported austerity policies threatens
to unravel progress further, as the Fund’s power and influence have
surged in the crisis.
Against this backdrop, the IMF is developing its first ever gender
strategy, under the leadership of recently appointed Senior Gender
Advisor Ratna Sahay (see Observer Summer 2021), with the ambition of
integrating a gender lens across the IMF’s core lending, surveillance
and technical assistance operations. A 23 March joint statement from
civil society and women’s rights organisations set out key policy
demands for the strategy, calling for the Fund to critically assess
the gendered impact of its conventional fiscal, monetary, structural
and labour market policy advice and to revisit its macro-economic
paradigm.
Gender equality is good for the economy – but is the opposite also
true?
Following an open letter signed by nearly 100 civil society
organisations (CSOs) calling on the IMF’s executive board to support
meaningful consultation on the strategy’s development, the Fund
opened an online public consultation on 10 February, and published a
concept note summarising its aspirations. The note reflected some
past civil society demands, although critical gaps remained. For
example, the impacts of fiscal austerity, regressive taxation and
labour flexibilisation on the feminisation of poverty have been
highlighted by the women’s rights movement and feminist economists
for decades, with many calling for systematic gender impact
assessments of IMF-promoted macroeconomic reforms, in line with the
2019 UN Guiding Principles (see Observer Spring 2019) and countries’
human rights obligations. The IMF started considering gender as a
macro-critical issue a decade ago, concentrating its research and
policy pilots on the economic gains from gender equity, while
refusing a human rights mandate.
The concept note acknowledges that, “the IMF is a late comer to the
field of gender,” emphasising the urgent need for the IMF to
consistently address gender disparities and assess “how macroeconomic
and financial shocks and policies affect men and women differently.”
Analytical models – previously lacking complexity – to predict the
gender-specific effects of macroeconomic reforms are to be refined,
and collaboration with experts, including academia and civil society,
expanded, aligning with recommendations from the IMF’s Independent
Evaluation Office. Most importantly, the concept note echoes a 2018
IMF staff guidance note on operationalising gender, which stressed
that “at the very least, IMF policy advice should not exacerbate
gender disparities” (see Observer Summer 2021; Briefing, The IMF and
Gender Equality: Operationalising Change).
Despite these assertions, little light was shed on the effects of
Fund-endorsed macroeconomic policies on gender inequality, women’s
poverty rates, care burdens and ability to access decent work, nor on
the IMF’s intentions to measure and address them. Without this
analysis, the Fund risks undermining even its own narrow goals to
promote growth through women’s economic empowerment, as reforms meant
to bolster women’s productivity may be offset by other gender-blind
policies.
Instead, the note asserted the IMF’s ambition to scale up its
country-level policy advice and loan conditionalities pushing members
to close gender gaps deemed to affect the macro environment. This
could mean the Fund assuming a new role as a global expert body on
gender issues in macroeconomic policy – a highly problematic
development without a much more serious examination of gendered
effects of other policies promoted by the Fund, such as its continued
focus on fiscal consolidation, export-led growth, liberalised capital
flows, central bank independence and financial deepening. Austerity
will impact 6.6 billion people in 154 countries in 2022 (see Observer
Autumn 2020), while “the implicit assumption of these gender-blind
policies is that women will absorb the shock of fiscal cuts,”
according to Bhumika Muchhala of Malaysia-based CSO Third World
Network. A 2 March letter by four UN Special Rapporteurs and
Independent Experts on debt, development, and human rights stressed
that, “Adding a gender strategy to a host of other strategies and an
operating system which are gender-blind will not help address the
needs of women and girls and end the systemic drivers of their
disadvantage and exploitation.”
What a commitment to ‘do no harm’ means in practice
The statements by both UN experts and civil society called on the IMF
to lay out an institutional framework committed to pursuing an
“alternative policy mix” that upholds women’s economic and social
rights from the outset. Professor Diane Elson of the University of
Essex stressed that “it should be mandatory for all loan conditions
to be subject to an ex-ante gender impact assessment. Where this
reveals a likely adverse impact on gender equality, the loan
conditions should be revised.” Ultimately, this should result in a
more fundamental revision of the Fund’s policy framework to
systematically promote alternative policies that maintain the
enabling conditions and fiscal space required to address structural
inequality. “Public expenditure should not be viewed as ‘consumption’
but ‘investment’ in the public goods required for women’s human
rights, such as health, education, and social protection,” explained
Muchhala.
The continued lack of committed resources in the IMF’s operational
budget to meaningfully scale up its intersectional gender analysis
and required staff capacity remains a key bottleneck. Gender was
clearly deprioritised in the most recent IMF work programme, the
2022-2024 mid-term budget and the 2021 Comprehensive Surveillance
Review (see Observer Summer 2021).
Given these constraints, meaningful and proactive engagement with the
vast body of existing expertise and lived experience held by women’s
rights groups, civil society and feminist economist scholarship will
be crucial. “Since the IMF is coming ‘late to the game’ by their own
admission, it’s even more critical that they get up to speed on the
extensive analyses of feminist economists who have already done the
work,” emphasised Pryanthi Fernando, executive director of
International Women’s Rights Action Watch (IWRAW) Asia Pacific.
Partnerships with other expert organisations should be formalised,
documenting shared objectives and the delineation of mandates, and
the IMF should participatively develop a civil society engagement
policy.
While the strategy is set to be published in spring 2022, civil
society will closely monitor its implementation, and continue to hold
the IMF accountable on women’s rights.
bit.ly/IMFGender

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In this issue

- New IMF Resilience and Sustainability Trust (RST) – how to make it
work for the Global South by Tirivangani Mutazu
- World Bank’s re-labelled Business Enabling Environment Project does
little to address substantial flaws of Doing Business Report
- World Bank announces support for CCUS in Nigeria despite criticisms
it reinforces fossil fuel dependence
- IMF programme in Pakistan undermines renewable energy roll-out by
Zain Moulvi

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GENDER/news

The Bretton Woods Project welcomes new gender project staff

BWP is pleased to welcome Friederike Strub as our Gender Equality and
Macroeconomics Lead and Amy McShane as Gender Project Officer.
Working together on BWP’s Gender Equality and Macroeconomics (GEM)
project, Friederike and Amy will lead the charge on challenging the
ways in which macroeconomic policies currently promoted by the World
Bank and IMF undermine gender equality.
Friederike previously led research and strategy design on women’s
economic empowerment, gender-based violence, and social norms as
Senior Gender Specialist at consulting firm MarketShare Associates,
as well as serving as legal analyst for Women, Business and the Law
at the World Bank. As a consultant for Oxfam America, she developed a
global programming strategy on women’s economic empowerment and
advised the US-based Coalition on Women’s Economic Empowerment and
Equality on advocacy strategy. Friederike holds an MA in Public
Policy from Harvard Kennedy School, and a BA in political science
from the University of Konstanz.
Before joining BWP, Amy managed a funding portfolio of Violence
Against Women and Girls (VAWG) grassroots organisations, as well as
leading on Monitoring and Evaluation (MEL) initiatives for two
specialised cohorts as a Senior Associate at Comic Relief, a UK-based
international charity. As a part-time journalist for several years,
Amy is a skilled storyteller and communicator. Amy holds an MSc in
Globalisation and Development from the School of Oriental & African
Studies (SOAS), where she focused on postcolonial critique of
hegemonic development discourse, and an MA in Politics and Sociology
from the University of Glasgow.
bit.ly/BWPStaff

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FINANCE/analysis

New IMF Resilience and Sustainability Trust (RST) – how to make it
work for the Global South
Guest analysis by Tirivangani Mutazu, AFRODAD

Summary
- The creation of a new IMF-administered Resilience and
Sustainability Trust (RST) is welcome, but its design shortcomings
must be resolved
- The RST’s purpose must be to support low- and vulnerable middle-
income countries to recover from the pandemic and tackle economic and
climate-related structural challenges
- RST design needs to be aligned with CSOs’ principles for fair and
transparent SDRs channelling

In August 2021, the IMF issued the largest-ever Special Drawing
Rights (SDRs) allocation in history – about SDRs 456 billion, the
equivalent of $650 billion. SDRs are an international reserve asset,
created by the IMF in 1969 to supplement its member countries’
official reserves (see Inside the Institutions, What are Special
Drawing Rights?). It serves as the unit of account of the IMF
(Observer Autumn 2021).
Although the $650 billion fell short of the $3 trillion allocation
that global debt networks advocated for in February 2021, SDRs have
greatly helped low- and middle-income countries finance their
economic recovery from the Covid-19 induced economic, health and
social impacts. Many countries in Africa, such as Ghana, Senegal, and
Malawi, have been able to use their SDR allocations to finance
Covid-19 programmes, procure vaccines, stock up their foreign
exchange reserves and support their productive economic sectors.
However, SDRs are distributed in proportion to member countries’ IMF
quota share (see Inside the Institutions, IMF and World Bank
decision-making and governance). Using this inequitable system, G20
countries received 70 per cent of SDRs, while developing countries in
dire need of liquidity received only 30 per cent. The Africa region
received just $32.3 billion of the $650 billion allocation. This
grotesque situation is why the Global South continues to call for IMF
reform, especially of the unequal quota system and SDR sharing rules
(Dispatch Annuals 2021).
Proposals for ‘channelling’ SDRs require an equitable approach
In October 2021, the G20 committed to ‘channelling’ $100 billion of
their SDRs to low-income countries, small island developing states
and climate vulnerable middle-income countries. The current proposals
for channelling include the IMF’s Poverty Reduction and Growth Trust
(PRGT), its new proposed Resilience and Sustainability Trust (RST),
multilateral development banks (MDBs), and bilateral arrangements,
where rich countries will on-lend their SDRs directly to other
countries.
The creation of the new IMF-administered RST is welcome, but its
design shortcomings undermine its principal purpose. The IMF has made
public that the RST is expected to be operational before the end of
2022, with an initial capital aimed at $50 billion – although the
US’s failure to approve reallocation of its SDRs in a spending bill
for this fiscal year raises the question of whether this target will
be met. Despite support from many rich countries, the RST is not an
adequate solution to SDRs channelling and its proposed features are
problematic for citizens in the Global South.
The current opaque design and operationalisation discussions between
RST contributor countries and the IMF – which have been characterised
by a lack of consultation with civil society – do not inspire
confidence that countries in need will benefit from the channelled
SDRs. The richer countries are seeking a mechanism that preserves the
asset value of their on-lent SDRs.
The RST design undermines the principle of country ownership, through
its focus on structural reforms, conditionality and climate change,
interfering in countries’ policy making. The proposed RST eligibility
conditions to qualify for support are also problematic. These include
a policy package reflecting the RST’s objectives, an existing IMF
programme, and a sustainable debt profile that is adequate to repay
the Fund. Proposed RST design features are incompatible with
supporting a sustainable, equitable recovery and do not align with
civil society organisations’ (CSOs) principles for fair and
transparent SDRs channelling.
For an effective and impactful new RST, civil society and
environmental groups make the following demands:
The RST’s purpose must be to support vulnerable low- and vulnerable
middle-income countries’ recovery from the pandemic and tackle
economic and climate structural challenges.
RST design should prioritise and balance the needs of borrowing
countries and SDRs contributors. Demands and voices of low- and
vulnerable middle-income countries must inform the RST’s ultimate
design.
RST design must align with borrower countries’ own priorities, rather
than creating new types of Northern-led conditionality.
The design of the RST should be informed by inclusive and deep
consultations with global civil society.
The RST should not be an instrument to bring harsh austerity policies
at the expense of social services in borrower countries.
Finance from the RST should not jeopardise debt sustainability, and
should provide debt-free financing, without policy conditionality.
RST must be accessible to middle-income countries, have transparency
and accountability safeguards, ensure that SDR contributions are
additional to existing ODA and climate finance commitments, and
provide grants that promote climate justice and tackle economic and
gender inequality.
All vulnerable countries should get support under the RST, and this
must not be contingent on having another IMF-supported programme.
RST must be part of broader reforms to international financial
architecture
The SDRs channelling debate reflects unfair global financial
mechanisms, especially in times of crisis. No new financial
instrument will succeed until the current global debt and financial
architecture is reformed. African countries face risks of recurrent
debt crises amid stiff resistance from creditors, especially private
creditors, for a new independent debt restructuring mechanism. The
international community must address illicit financial flows and
support initiatives that spur domestic resource mobilisation to
enable a successful fight against the pandemic.
The AFRODAD 2021 Inaugural African Conference on Debt and Development
outcome declaration, known as the Harare Declaration, called for,
“reforming of the global debt architecture in a manner that equalizes
the loan contraction processes – including reform of debt
sustainability frameworks and credit ratings assessment, and the
establishment of an African Accountability Mechanism that will act as
the foundation for enhanced transparency, accountability, and
governance of Africa’s debt architecture.” The RST, therefore, must
be people-centred in its design and operations, which will require a
departure from other IMF financing instruments in existence.
bit.ly/RSTGlobalSouth

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FINANCE/news

IMF capital control review: A missed opportunity to support a just
recovery and stability

Summary
- IMF executive board undertakes review of Fund’s institutional view
on capital controls
- Review crticised as timid for failing to recognise  control of
capital inflows and outflows as key component of macroeconomic
toolkit to increase policy autonomy

On 30 March, while welcoming the new view’s recognition that inflows
regulations should be in place and pre-emptive, the IMF published the
results of the executive board’s review of its Institutional View
(IV) on the Liberalisation and Management of Capital Flows. The
review was eagerly anticipated by policymakers, academics and civil
society, as it was hoped it would reflect available evidence and
recognise that regulation of capital flows should be an essential and
permanent part of States’ macroeconomic policy toolkit and therefore
significant depart from its predecessors (see Observer Winter 2021).
The Review revisited the institutional view from 2012, which was at
the time immediately criticised by Brazilian finance minister Guido
Mantega, who complained, “experience has shown that the free flow of
capital is not necessarily the preferable option in all
circumstances” (see Update 83, 80). A September 2020 evaluation by
the IMF’s Independent Evaluation Office (IEO) titled IMF Advice on
Capital Controls echoed some of these concerns (see Observer Spring
2021). While noting some progress, it highlighted that the Fund’s
advice on capital flows remains overly restrictive. Crucially, the
IEO suggested that a revised institutional view should allow pre-
emptive and more long-lasting use of capital flow measures (CFMs).
Review disappoints, as it preserves the bulk of previous policy
framework
Professor Kevin Gallagher of Boston University, while welcoming the
new view’s recognition that inflows regulations should be in place
and pre-emptive, lamented that it retained many of its predecessor’s
shortcomings. He stressed that the new view remains silent on the
need to regulate capital flows “to prevent massive capital flight is
still concerning” (see Observer Spring 2022). He similarly noted that
the review failed to address “the multilateral aspects of CFMs such
as the need to regulate capital flows on ‘both ends’ meaning also in
source countries and the need to reconcile IMF advice with the
thousands of trade and investment agreements that not only make CFMs
actionable but may trigger massive payouts to private investors.”
Finally, he cautioned that there remains a “real need to improve
implementation of existing and new institutional view. Evidence shows
it was given uneven treatment in first 10 years.”
The current view failed to respond to a call for a change to the
Fund’s institutional view made jointly by professor Gallagher and
Columbia University professor Joseph Stiglitz in a 7 March article in
Project Syndicate, in which they recommended that the IMF’s executive
board push for four reforms to the Fund’s capital-account policy: To
advise countries to enact permanent regulations allowing for the
rapid deployment of CFMs during surges and sudden stops; recommend
that CFMs be part of a multi-pronged approach; support reforms to
trade and investment treaties to grant emerging market and developing
countries more autonomy to use CFM; and ensure staff are trained to
implement new policies.
Daniela Prates from the UN Conference on Trade and Development
concurred with Gallagher, calling the review “timid”, noting that the
Fund stated that the general recommendations remain unchanged. Prates
said that considering pre-emptive CFMs and macroprudential measures
solely in cases of systemic risks when other measures are inadequate
remains very restrictive, stressing that “CFM in general are
important to increase policy autonomy of middle- and low-income
countries and enable them to maintain a competitive exchange rate”
(see Observer Winter 2021). She further noted that the review does
not consider the fact that currency mismatches can also occur within
the public sector, and that it fails to consider the specificity of
the context of middle- and low-income countries that results in
systemic risks associated with currency mismatches.
Kavaljit Singh, Director of India-based non-profit organisation
Madhyam, echoed Prates and Gallagher, stressing that, “A closer
reading of the 98-page review of the Institutional Review reveals
that it does not propose any fresh thinking or a new macroeconomic
framework on managing cross-border capital flows and therefore cannot
be considered as a major departure from the 2012 IV. Rather, it
reaffirms the core principles and intellectual underpinnings of the
2012 IV. Except for allowing capital flow management measures (a la
capital controls) pre-emptively on inflows and listing out some
exceptions (such as national security and tax-related matters), the
review preserves the bulk of the policy framework outlined in the
2012 IV and therefore is a sheer disappointment.”
bit.ly/CapitalFlowsReview

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KNOWLEDGE/news

World Bank’s re-labelled Business Enabling Environment Project does
little to address substantial flaws of Doing Business Report

Summary
- World Bank announces move towards rebranded Business Enabling
Environment Project which fails to address underlying issues
previously raised by civil society
- Civil society calls for urgent evaluation of Doing Business impacts
and rethinking of private sector strategy at the Bank

When the World Bank’s Doing Business Report (DBR) was cancelled late
last year, civil society organisations (CSOs) celebrated what was
perceived to be a success (see Observer Autumn 2021). Those concerned
about the Bank’s intentions moving on from the damning investigation
saw the DBR’s cancellation as an opportunity to call for a complete
overhaul of the World Bank in an open letter signed by 143 CSOs and
academics on 12 October. The elation was short-lived, with the World
Bank announcing in February the creation of a new Business Enabling
Environment Project (BEEP) (see Observer Winter 2021) and releasing a
pre-concept note shortly after. The ‘Rights not Rankings’ coalition,
a group of CSOs that had closely been following the DBR and now BEEP
process, responded with a joint submission urging the Bank to halt
the project unless several key issues are addressed.
The coalition’s initial 12 October letter had asserted the need for
structural changes to the World Bank’s neoliberal paradigm and its
“ideological bias…in favour of austerity, deregulation, and
privatisation that systematically reduces countries’ fiscal and
policy space and hollows out the state.” It also advocated for an end
to the IMF and World Bank’s undemocratic governance, such as the
gentleman’s agreement (see Background, What is the ‘gentleman’s
agreement’?). Moving forward to the BEEP consultation, the coalition
pointed out that there is little meaningful difference between DBR
and BEEP. Seven members of the coalition contributed to the newest
submission in March, as part of the consultation period. It
summarised that the proposed BEEP “replicates a model of business and
private sector development that promotes an increase in corporate
power and concentration, the accumulation of obscene amounts of
wealth, proliferation of tax dodging and tax havens, and the
deepening of an unequal global division of labour through
environmentally unsustainable global value chains.”
Alex Cobham of the Tax Justice Network questioned BEEP’s lack of
substantive evidence to support the need for a ‘business enabling
environment’ at all in a recent blog post, noting that the pre-
concept note hints at outcomes such as ‘growth’, ‘equality of
opportunity’ and ‘sustainability’ being linked to ‘private sector
development’, yet fails to demonstrate the existence of any causal
relationships between these factors.
World Bank’s own evaluation points to lack of evidence for successful
reforms
This lack of evidence has been pointed out by the World Bank’s own
Independent Evaluation Group, which published a 2010-20 review of DBR
on 15 March, highlighting that DBR scores were based on narrow
indicators which did not account for country-specific conditions such
as fragility and conflict, cultural difference in business custom,
and alternative development priorities, so could not provide accurate
evaluations of impact reforms had. The report recommended that the
Bank should therefore “avoid using DB [Doing Business] indicators as
explicit reform objectives or monitoring indicators,” and called into
question the “objectivity and accuracy” of the resource, stating that
“DB reports have made many claims for the benefits of measured
reforms that go beyond rigorous or replicated evidence.”
More positively, BEEP is considering removing the ranking process.
This is significant, as the DBR rankings were deemed a “regressive”
system that promoted “a race to the bottom of business deregulation,
eroding tax and social security systems, and removing critical
workers’ protections” in a September 21 civil society statement (see
Observer Winter 2019). Additionally, BEEP will consider de facto
changes in a country’s business environment by incorporating surveys
with businesses, rather than merely recognising de jure changes that
may not actually be implemented, as the DBR did.
Looking forward, the coalition asks the Bank to evaluate impact on
poverty, inequality and human rights of the implementation of 18
years of DBR-inspired policy reforms, rethink its understanding of
privatisation (particularly in the context of Covid-19 recovery, and
the inequality and climate crises), and address deep structural
disparities uncovered by civil society. Speaking on behalf of the
coalition, Flora Sonkin of Society for International Development
(SID) stated, “Instead of rebranding the DBR, the World Bank should
be taking a hard look at the harmful impacts its flawed policy advice
have caused for the past 18 years and work towards reparations and
accountability.”
bit.ly/BEEP2023

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INFRASTRUCTURE/analysis

World Bank announces support for CCUS in Nigeria despite criticisms
it reinforces fossil fuel dependence

Summary
- World Bank trust fund ESMAP to provide support for developing
domestic Carbon Capture, Utilisation and Storage (CCUS) market
- IFC seeks to crowd in private sector into CCUS in Nigeria
- CCUS projects have been widely promoted by fossil fuel companies,
despite lack of evidence that they deliver meaningful climate change
mitigation

The World Bank announced on 10 February that it will work to develop
a domestic market for carbon capture, utilisation and storage (CCUS)
in Nigeria in its latest embrace of the controversial technology,
which has been criticised as an ineffective ‘techno-fix’ to the
climate crisis by civil society.
A February press release by the International Finance Corporation
(IFC), the World Bank’s private investment arm, stated, “IFC will
work with the [Nigerian] government to identify the most promising
sectors and private companies that can pilot new technologies for
capturing, using, and storing carbon.…In parallel, the World Bank
will collaborate with the Nigerian Government to outline policies and
regulations that can accelerate the technologies’ uptake while
helping the local CCUS industry meet international standards.”
The release added that, “The project is funded by the World Bank’s
CCS [Carbon Capture and Storage] Trust Fund under the Energy Sector
Management Assistance Program (ESMAP),” which is supported by the UK
and Norway.
According to the US-based Center for International Environmental Law
(CIEL), CCUS technologies, “refer to processes that collect or
‘capture’ carbon dioxide generated by high-emitting activities – such
as coal- and gas-fired power production or plastics manufacturing –
and then transport those captured emissions to sites where they are
either used for industrial processes or stored underground.”
CIEL noted in a July 2021 briefing that, “The unproven scalability of
CCS technologies and their prohibitive costs mean they cannot play
any significant role in the rapid reduction of global emissions
necessary to limit warming to 1.5°C.…The 28 CCS facilities currently
operating globally have a capacity to capture only 0.1 percent of
fossil fuel emissions.” The briefing also points out that a
significant proportion of CCUS operations to date are focused on
‘utilising’ fossil fuel waste products by injecting them into
underground oil reservoirs, in an effort to increase oil production.
The briefing laments that, “waste products from a fossil fuel-burning
activity are used to generate more fossil fuels, propping up the
unsustainable fossil fuel energy system.”
World Bank and its MDB peers keep the faith in false CCUS solutions
The World Bank announcement comes as CCUS continues to be widely
promoted by the fossil fuel industry as a way to bring its activities
in line with global climate goals, with multilateral development
banks (MDBs) and wealthy governments – including the UK – supporting
these efforts.
Despite claims that CCUS largely reinforces the fossil fuel energy
status quo, the updated joint MDBs methodology for tracking finance
for climate change mitigation, released in October 2021, continues to
classify CCUS as climate finance, noting, “In addition to post-
combustion capture, financing provided specifically to enable pre-
combustion capture or separation of oxygen from air for oxyfuel is
eligible [to be classified as MDBs climate mitigation finance].”
This raises the possibility that CCUS could form a pillar of the
MDBs’ efforts to align their activities with the Paris Agreement
going forward, despite the lack of credible evidence that CCUS
represents a durable solution to averting catastrophic climate
change. The World Bank has pledged to align most of its financing and
other activities with the Paris Agreement by 1 July 2023 (see
Observer Summer 2021), while the IFC’s press release for the Nigeria
CCUS project claims the initiative, “could accelerate the energy
transition and help Nigeria reach its emissions targets.”
Meanwhile, the UK – which, as the host of the UN Framework Convention
on Climate Change’s 26th Conference of Parties (COP26) in Glasgow in
November 2021 (see Observer Winter 2021), has been keen to project an
image as a global leader on climate issues – is the largest financier
of the multilateral CCUS agenda. The UK funds efforts at both the
World Bank and Asian Development Bank, via the UK Department for
Business, Energy and Industrial Strategy’s (BEIS) £70 million
international CCUS programme, and counts this programme as part of
its international climate finance commitments.
However, a 2021 review of the UK’s CCUS programme, which has focused
on Indonesia, South Africa, China and Mexico since 2012, found it,
“does not represent good value-for-money,” due to ongoing setbacks
with CCUS pilot projects.
As the BEIS review sets out, the programme’s struggles are indicative
of a broader global trend, with CCUS failing to deliver on the high
hopes its advocates have placed on it. The review notes, “Global
progress on CCUS is well off-track to reach the expectations set out
in the IEA’s [International Energy Agency] Sustainable Development
Scenario, with the IEA describing the story of CCUS as ‘one of unmet
expectations’.”
Civil society advocates argue that this demonstrates the need to
rapidly shift beyond CCUS to fossil fuel alternatives. “No amount of
investment in CCS can accelerate the needed transition to a fossil-
free future,” said Nikki Reisch of CIEL. “CCS locks in place
polluting industries and compounds their harms to communities,
prolonging the use of fossil fuels precisely when we need to be
replacing them with renewables.”
bit.ly/CCUSNigeria

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ENVIRONMENT/commentary

IMF programme in Pakistan undermines renewable energy roll-out
Guest comment by Zain Moulvi, Alliance for Climate Justice and Clean
Energy (Pakistan)

Summary
- Civil society raises alarm as IMF programme undermines Pakistan’s
national climate plans
- Tax breaks on renewables and EVs slashed from IMF-mandated mini-
budget

On 13 January, the Government of Pakistan (GOP) introduced a
controversial set of fiscal reforms in order to revive the
International Monetary Fund’s (IMF) $6 billion Extended Fund Facility
(EFF) for the nation, originally approved in 2019. These reforms
include a devastating regime of new taxes on solar panels, wind
turbines, electric vehicles and related technologies, which are
likely to cripple Pakistan’s nascent renewables energy market,
derailing the country’s energy transition and threatening its
international climate obligations.
Pakistan was forced to adopt these measures to meet the Fund’s
conditions for the release of the next $1 billion tranche under the
stalled EFF programme, as agreed by the IMF executive board on 2
February. Instituted through a hastily prepared supplementary finance
bill and bulldozed through the national assembly, these reforms have
overturned the previous policy of tax exemptions on renewable
technologies, resulting in a 20 per cent tax on solar and wind
technologies, as well as a 12 per cent increase in sales tax for
imported electric vehicles (EVs). This policy shift comes despite the
encouraging growth of the renewables sector under the previous tax
regime.
The unprecedented rise in solar photovoltaic (PV) installations in
Pakistan’s off-grid and weak grid regions in recent years has been a
windfall for vulnerable communities. Buoyed by the GOP’s decision to
waive taxes on solar products in 2014, the growth reflects solar’s
suitability for powering tube wells, water pumps and purification
systems for drinking water and irrigation in remote and water-
stressed areas. The primary beneficiaries of this boom have been poor
farming communities – especially women – who have historically
struggled with access to electricity and water. Solar technology,
however, is still a largely import-based market, and growth is likely
to be slowed with users unable to meet higher prices.
The new tax reforms are also set to disrupt Pakistan’s strategies for
decarbonising its energy and transport sectors as laid out in its
Alternative and Renewable Energy Policy (ARE) and in its National
Electric Vehicle Policy (NEV), both published in 2019. Pakistan’s
roadmap for displacing entrenched fuel sources depends heavily on the
integration of cheap renewables into on-grid and off-grid solutions,
private contracts, and rural energy services. The ARE policy sets a
minimum target of 30 per cent renewable-based power generation in the
national grid by 2030, which requires large scale “buy-ins” from
existing fuel-based producers and self-generating agricultural and
industrial consumers, incentivised for example through lower tariffs
for utility scale solar/wind power currently in place. The 20 per
cent tax on renewables, however, will also hit inverters, batteries,
and other renewables-related installation equipment and machinery.
This will significantly raise upfront capital expenditure for such
projects, increasing their overall generation costs and reducing
their competitive advantage.
The increased tax on EVs also jeopardises the target of 30 per cent
of vehicle sales for EVs by 2030 prescribed by the NEV policy.
According to the policy, robust tax incentives are essential for
developing the fledgling import-based market and for encouraging
adoption of EVs amongst the masses. Under the new tax regime, users
in the energy and transport sectors are unlikely to opt out of
existing fuel-based arrangements, side-lining a key mechanism for
reducing emissions.
Despite new climate strategy, the IMF fails to match rhetoric with
action
That such environmentally damaging and contradictory policy outcomes
are directly tied to an IMF programme that waxes eloquent about
“stepping up to climate change,” reflects the self-defeating nature
of the IMF’s structural adjustment programmes and the distortive
effects of its lending practices. It also raises concerns about the
sincerity of the Fund’s commitment to global climate goals, after it
launched a new climate strategy in July that seeks to mainstream
climate across all areas of its mandate (see Observer Autumn 2021).
There is an obvious misalignment between the Fund’s policy advice and
lending conditions, and its public rhetoric on supporting low-carbon
transitions. The Fund’s new strategy, for instance, emphasises the
need for favourable “tax regimes” and “structural and spending
policies” for climate-vulnerable countries. The staff statement on
Pakistan’s EFF programme explicitly identifies its particular
vulnerability as one of “top ten countries with the largest damages
from climate-related disasters, and top 20 countries with the largest
greenhouse gas (GHG) emissions,” as a pressing concern. It recommends
policy steps such as the “wider use of renewables”, “implementation
measures for meeting Pakistan’s COP 26 targets”, and the securing of
“sufficient financing” for the energy transition as “critical”
priority areas. Yet it is these very goals and measures that are
sabotaged by the EFF’s loan conditionalities with environmental
consequences that extend to the international front.
The IMF needs to ensure that these harmful taxes are withdrawn. It
also needs to adopt concrete mechanisms for harmonising its policy
advice with recipient governments’ national climate goals, as well as
with global climate agreements. Part of the solution lies in
correcting its insular approach to loan programme development. A
policy of meaningful civil society consultation – especially with
vulnerable groups – along with independent, ex-ante reviews of the
consequences of the proposed fiscal adjustments, is imperative if the
Fund’s stated aims of countering “climate change” and fostering
“sustainable growth” are to progress beyond empty rhetoric. This
along with green financing solutions such as debt-for-nature swaps
and debt forgiveness is the need of the hour for nations like
Pakistan which have found themselves trapped in a vicious cycle of
debt over years of failed IMF interventions.
bit.ly/PakistanRenewables

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FINANCE/news

Calls for Ukraine debt relief grow as IMF and World Bank provide
fresh loans amidst crisis

Amidst the worsening conflict in Ukraine, Ukrainian activists and
international allies have called for the country’s unsustainable
debts to be written off – including those owed to multilateral
institutions such as the IMF and World Bank.
Ukraine’s external debt stood at $56.7 billion at the end of 2020,
according to the IMF. Jubilee USA executive director Eric LeCompte
noted in a 8 March article in Barron’s magazine that Ukraine owed $22
billion to international finance institutions (IFIs), stating: “The
IMF holds more than a half of that…debt at $13.4 billion with $2
billion in debt payments owed this year…. Since Ukraine will most
likely default on these payments, the IMF should act quickly to
restructure the payments.”
The Fund’s executive board subsequently approved a $1.4 billion loan
to Ukraine on 9 March via its Rapid Financing Instrument, while the
World Bank also released a $723 million financing package on 7 March,
including $589 million in new loans. While this financing provides
much needed emergency support, it increases Ukraine’s substantial
debt load further.
Ukraine is also being charged significant surcharges on its loans by
the IMF, as a result of its borrowing being in excess of its IMF
quota allowance (see Observer Spring 2022, Winter 2021). According to
Belgium-based civil society network Eurodad, Ukraine is projected to
pay $178 million in surcharges in 2022 alone.
“It just doesn’t make sense for countries like Ukraine to send tens
of millions of dollars every month to fund the IMF in Washington as
they confront war, pandemic, and economic crisis,” said US
Congressman Jesús “Chuy” García, in a March press release announcing
a new bill aimed at getting the US Treasury to support a suspension
of IMF surcharges, pending a review.
bit.ly/UkraineDebt

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SOCIAL SERVICES/news

Civil society hails IFC’s divestment from for-profit education
provider Bridge International Academies

After a long-running civil society campaign, the International
Finance Corporation (IFC), the World Bank’s private investment arm,
announced on 9 March it was divesting from New Global Schools,
previously known as Bridge International Academies (BIA). BIA, a for-
profit education provider, had received $13.5 million from the IFC
since 2014 to support its operations in Kenya, Liberia, Uganda,
Nigeria and India.
The divestment follows a 2020 freeze in new IFC direct and indirect
investments in for-profit education providers, which was a condition
of US Congress’s support for a new IFC capital increase (see Observer
Summer 2020, Winter 2019).
“The BIA model and its implementation undermined the right to
education and the rule of law in Uganda,” said Salima Namusobya of
Uganda-based civil society organisation (CSO) Initiative for Economic
and Social Rights, in a 16 March press release. “The IFC divestiture
comes at a time when a majority of BIA schools have closed down since
their for-profit model was unsustainable, particularly in the wake of
COVID-19. We hope other investors will follow suit.”

BIA’s for-profit model has attracted sustained condemnation in recent
years. In 2016, IFC’s support for BIA in Liberia was criticised by
the UN Special Rapporteur on the Right To Education, Kishore Singh,
who argued, “provision of public education of good quality is a core
function of the state. Abandoning this to the commercial benefit of a
private company constitutes a gross violation of the right to
education” (see Observer Summer 2016).
In 2018, 88 CSOs called for IFC to divest from BIA in an open letter,
highlighting a series of issues with its operations, including,
“higher costs than those advertised by the company, failure to
register schools, use of unapproved curriculum, failure to meet
teacher certification requirements, and discriminatory impacts” (see
Observer Spring 2018).
A 2019 report by the Compliance Advisor Ombudsman (CAO), the IFC’s
independent accountability mechanism, following a 2018 complaint
against BIA in Kenya, highlighted concerns about BIA’s lack of
“adherence to relevant health and safety requirements,” and the
potential “adverse impacts to teachers, parents and students raised
in the complaints” (see Observer Winter 2019).
bit.ly/IFCBridgeAcademies

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DEBT/news

Ineffective G20 Debt Service Suspension Initiative ends as world
faces worst debt crisis in decades

Summary
- Countries due to resume debt payments amid unequal pandemic
recovery
- CSOs call for debt cancellation and a multilateral debt workout
mechanism

With solutions to the ongoing debt crisis yet to be reached, progress
is urgently needed. The end of the G20’s Debt Service Suspension
Initiative (DSSI) in December 2021 means that countries are due to
resume payments on their debt obligations despite a deteriorating
global context, particularly for middle- (MICs) and low-income
countries (LICs).
Of the 73 LICs eligible for the DSSI, only 43 applied for a total of
$13 billion of debt service suspension – accounting for just a
quarter of the amount the G20 announced the DSSI would deliver in
April 2020 (see Observer Winter 2021). The fact that the DSSI only
temporarily suspended bilateral debt payments, along with the lack of
private sector involvement in the scheme, contributed to the
mechanism being ineffective. This happened in spite of civil society
warnings (see Dispatch Annuals 2021) and IMF leadership acknowledging
that, “It is also critical that private sector creditors implement
debt relief on comparable terms.”
A January analysis by UK-based Jubilee Debt Campaign (JDC) found that
“54 countries globally are in debt crisis, meaning that debt payments
are undermining the ability of governments to protect the basic
economic and social rights of their citizens.” According to an
article by US-based think tank Atlantic Council, “these LICs face
debt-service payments worth $11 billion more this year…threatening to
crowd out urgently needed public spending on health, social services,
and other development needs.”
On 18 January, World Bank President David Malpass tweeted: “With too
many developing countries facing record levels of external and
domestic debt, we cannot afford to wait any longer. The world’s
poorest urgently need deep debt relief, enhanced debt transparency
and a rebalancing of creditor/debtor powers.”
Deepening the divergent recovery
The DSSI did nothing to address countries’ long-term debt
obligations, which were exacerbated by the pandemic. On top of this,
the Ukraine crisis will worsen the outlook for many countries already
in debt distress (including in Sub-Saharan Africa) as the cost of
importing key commodities rises, exacerbating their balance of
payments difficulties, including their ability to service debts (see
Observer Spring 2022). Meanwhile, countries in debt distress like
Zambia are being forced to make payments to private creditors such as
BlackRock, at the expense of their own population’s wellbeing.
The already divergent recovery from the Covid-19 pandemic will likely
be exacerbated by high-income countries’ (HICs) adjustments to their
monetary policies as their economies begin to recover. As the IMF
noted in an April 2021 blog, MICs and LICs will be adversely impacted
by higher interest rates in HICs, as these draw capital away from
MICs and LICs, resulting in a depreciation of their currencies and
therefore an increase in their debt obligations issued in foreign
currencies. The Ukrainian situation has worsened this trend, as in
times of crisis investors seek safety in assets such as the US
dollar. This strengthens the dollar versus other currencies,
exacerbating the trends above.
Steps taken thus far to address the debt situation caused by the
pandemic have been insufficient, as they failed to cancel debt as
academics and civil society have demanded (see Observer Winter 2021).
Numerous calls from CSOs, academics and debt experts for a United
Nations-based debt workout mechanism that, as noted by Patricia
Miranda of South and Central American CSO network Latindadd,
“ensure[s] a future of responsible lending and borrowing together
with regulation based on human rights and gender justice,” have
failed to materialise (see Dispatch Annuals 2020).
Additionally, other structural issues that contribute to an
exacerbation of the debt crisis and unequal pandemic recovery, such
as the IMF  surcharges policy (see Inside the Institutions What are
IMF surcharges?; Dispatch Springs 2021) and the Fund’s restrictive
institutional view on capital controls (see Observer Spring 2022)
must also be addressed if the world is to resolve the current debt
crisis, which will continue to hit the poorest and most vulnerable
the hardest.
bit.ly/DSSIDebt

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Argentine civil society denounces new IMF agreement as illegitimate

Summary
- IMF and Argentina agree the country’s 22nd IMF programme
- Street protests erupt amidst calls for rejection of the agreement
as civil society stresses debt is illegitimate

As reported by Al Jazeera, the Argentine Senate voted on 18 March to
proceed with a 30-month Extended Fund Facility (EFF) arrangement of
$45 billion or 1000 percent of the country’s quota. The programme was
agreed days ahead of a payment of $2.8 billion to the IMF as part of
a record-breaking $57.1 billion loan agreed in 2018 (see Observer
Winter 2018, Summer 2018). The Fund’s executive board approved the
programme on 25 March, paving the way for the initial disbursement of
$9.7 billion. However, echoing concerns about the 2018 programme, a
25 March IMF press release, stressed that, “Risks to the program are
exceptionally high and spillovers from the war in Ukraine are already
materializing…early program recalibration, including the
identification and adoption of appropriate measures…will be critical
to achieve the program’s objectives.” The agreement enables Argentina
to repay the previous 2018 Stand-by-Agreement (SBA), which has
repayments of $39 billion due in 2022-2023, and to strengthen its
international reserves.
Legal suit alleges that IMF loan violated Argentine law and human
rights
On 10 March a group of more than 120 people, filed a collective
action suit challenging the validity and constitutionality of the SBA
in a Federal Court, arguing that the lack of legislative approval “as
established by the Constitution...violates the right [to
participation] recognised in the Universal Declaration of Human
Rights in its art. 21, the International Covenant on Civil and
Political Rights in its art. 25 and the American Convention on Human
Rights in its art. 23.” On 29 March senators from Frente de Todos
(Everyone’s Front) proposed legislation to create a national fund,
projected to amount to as much as $20 billion, to pay the IMF with
funds recovered from those who have undeclared assets overseas and
contributed to capital flight during the 2018 SBA.
Civil society calls IMF debt odious and demands cancellation
A 11 March blog by the Movement for the Suspension and Investigation
of the Debt website reported on protests of tens of thousands
throughout the country against the new agreement. The Movement
maintains that the 2018 debt to the Fund should not be paid, as it is
illegitimate. It emphasises that the Fund’s evaluation of the
country’s compliance with the agreement every three months implies,
“increases in taxes and inflation, labour precarisation, increased
and damaging extractionism, loss of sovereignty...and
worsening...access to basic human rights.”
Speaking at a 14 March public hearing organised by the Frente de
Izquierda (Front of the Left) parliamentary bench, Nora Cortiñas, one
of Argentina´s Mothers of May Square-founders, described the
agreement as “fraudulent and odious, contracted against the interest
of the nation and its citizens.” She called on legislators to “vote
against the new loan so as not to betray the people.”
New research asserts programme violated IMF Articles of Agreement
In a 7 March article posted on Social Science Research Network,
Karina Patricio Ferreira Lima of University of Leeds (UK) and Chris
Marsh of Exante Data argued that, “the 2018 SBA violated the core
purposes of the IMF as per its Articles of Agreement and, therefore,
constitutes an ultra vires act,” making it invalid and void. The
violations included failure to ensure adequate safeguards for the
provision of the Fund’s general resources in light of unsustainable
debt and inaction on capital controls, for example, to ensure the
programme did not contribute to an extension and severity of
Argentina’s balance of payments crisis. The analysis is supported by
a December 2021 North American Congress on Latin America article
outlining the programme’s numerous irregularities and political
motivations.
Political neutrality of 2018 programme questioned
The IMF’s own analysis in its Ex-post Evaluation (EPE) of the 2018
SBA notes that, “The program was well understood to be high-risk—from
the beginning, public debt was assessed to be ‘sustainable but not
with high probability. ...[the] reintroduction of capital flow
management measures, could have delivered a more robust program.” The
Argentine Government’s official response to the EPE stressed that,
“the discrepancy between the technical views of the staff and the
decisions made by the IMF reinforce the view that the program
constituted...a loan that meant to support the electoral chances of
the incumbent Administration.” This interpretation is supported by a
December 2021 Forbes article referencing remarks by former US IMF
Executive Director Mauricio Claver-Carone that, “Argentina, under
Macri, was seen as a key ally of the United States…A return of
Peronism…would lead to an erosion of support for US interests in the
region.”
In response to the approval in the Congress on 11 March, several
deputies from the government coalition who voted against the motion
produced a document detailing the damaging legacy of the Fund in the
country, noting the positive trends in employment, poverty and
inequality during the Fund’s absence in the period after Argentina’s
default of 2001. It criticised the IMF for, “developing a programme
[in 2018] plagued by ‘irregularities’”, which “were not only due to
the excess of the quota that determines the maximum amount of
financing that the country can obtain from the IMF (around 18 billion
dollars) but also to the fact that this credit was used to finance
capital flight abroad.” The document’s authors stressed that the
Agreement “does not” guarantee “the sustainability of the debt after
2025, when…the repayment…begins.” They added that the country
requires a longer repayment timeframe and decried the fact that the
programme did not address the issue of the payment of surcharges,
which two former UN Independent Experts on Foreign Debt have argued
are contrary to international law and are widely considered counter-
productive and procyclical (see Observer Spring 2022, Winter 2021).
bit.ly/ArgentinaLoan

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RIGHTS/news

Report implicates IFC investments in human rights abuses of Uyghur
and other minorities in China

On 16 February, US-based think tank Atlantic Council, together with
DFRLab, Sheffield Hallam University, Helena Kennedy Center for
International Justice and NomoGaia, published a report alleging that
investments by the International Finance Corporation (IFC), the World
Bank’s private sector lending arm, have contributed to grave human
rights violations of Uyghur and other minorities in China.
The report noted that, “significant evidence suggests that several of
IFC’s clients are active participants in the implementation of PRC’s
[People’s Republic of China] campaign of repression against the
Uyghurs, including through forced labor, forced displacement,
cultural erasure, and environmental destruction.” Research undertaken
by the authors indicates that the IFC currently has approximately
$486 million in direct loans and equity investments in four companies
operating in the Uyghur Region.
The report made several recommendations based on these findings. It
called on the IFC and other development finance institutions (DFIs)
to divest from all corporate investments in the Uyghur Region;
recommended that the IFC and other DFIs presume that all companies
operating in the region are engaged in forced labour and carry risk
of complicity in the ongoing genocide; and that the IFC and other
DFIs should review and adjust their direct and indirect investment
portfolios to move sub-investments, sub-contracts and supply chains
out of the Uyghur Region. The report also noted that the IFC should
conduct a full review of its portfolio, including financial
intermediary investments, using the methods employed in the report.
Commenting on the report authors’ interactions with the IFC, Kendyl
Salcito of US-based non-profit NomoGaia lamented that, “We alerted
IFC personnel to the grave human rights risks associated with these
investments in November 2020, and we provided them evidence of
confirmed forced labor transfers and other harms in early February
this year. IFC has provided no indication that it will act to halt
these abuses.” She added that, “IFC isn’t responding to the press,
the member governments or us about how they plan to act on these
findings. The Bank has made no public statements about our report,
let alone about the ongoing genocide in the region. The lack of
accountability is staggering.”
bit.ly/IFCChina

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DEBT/news

Civil society campaign urges IMF to stop using punitive surcharges

With alarm growing over widespread unsustainable debt levels and
divergent pandemic recovery trajectories, a group of over 250 civil
society organisations (CSOs) and experts has called on the IMF
executive board to eliminate harmful surcharges in a public letter
ahead of the 2022 World Bank and IMF Spring Meetings. The signatories
expressed serious concern that “the IMF continues to levy punitive
fees on countries facing debt distress while struggling against the
effects of the pandemic,” demanding “the immediate suspension or
outright elimination of this policy”, in line with previous calls
from development experts, economists, CSOs and governments that
“surcharges need to go.”
Surcharges are levies the IMF adds to particularly large and long-
term loans, which will cost countries in debt distress an estimated
$7.9 billion over the next six years (see Inside the Institutions,
What are IMF surcharges?). The CSO initiative is bolstered by a host
of recent articles and briefings that have pointed out that
surcharges are “counterproductive and unfair” and undermine debt
sustainability (see Observer Winter 2021, Summer 2021; Dispatch
Annuals 2021). The letter highlights that surcharges “jeopardize the
recovery of countries facing severe economic difficulties,” while
“turning the pandemic into a profit opportunity for the IMF.”
A December 2021 IMF board discussion revealed split opinions: Most
executive directors signalled openness to a holistic review of the
policy, while others only supported temporary relief, and a small
group refused to consider any revision to the policy. With war-torn
Ukraine one of the major surcharge payers, the US’s blocking stance
is receiving domestic pushback from US lawmakers urging their
government to abolish surcharges, and introducing a bill to that end
on March 8 (see Observer Spring 2022).
bit.ly/SurchargesCampaign

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