Evaluation of EXIM's Environmental Effects Consideration

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Date Issued

Monday, September 29, 2025

Submitting OIG

Export-Import Bank of the United States OIG

Agencies Reviewed/Investigated

Export-Import Bank

Report Number

OIG-EV-25-01

Report Type

Inspection / Evaluation

Agency Wide

Yes

Number of Recommendations

Questioned Costs

Funds for Better Use

Report updated under NDAA 5274

Open Recommendations

This report has 7 open recommendations.

Recommendation Number	Significant Recommendation	Recommended Questioned Costs	Recommended Funds for Better Use
1	No	$0	$0
EXIM’s Office of the Chairman, in coordination with the Office of Policy Analysis and International Relations, the Office of Board Authorized Finance, and Office of General Counsel, should propose updated Environmental and Social Due Diligence Procedures and Guidelines for Board review and approval that incorporates, as necessary, revisions of applicable international standards.
2	No	$0	$0
EXIM’s Office of the Chairman, in coordination with the Office of Policy Analysis and International Relations, the Office of Board Authorized Finance, and the Office of General Counsel, should produce updated Environmental and Social Due Diligence Procedures and Guidelines for Board review and approval that clarify whether and, if so, how the ESPG relates to domestic transactions.
3	No	$0	$0
The Office of General Counsel should produce a written opinion on the circumstances under which Board members may withhold or approve transaction based upon environmental effects.
4	No	$0	$0
EXIM’s Office of Board Authorized Finance should establish policies and procedures establishing clear milestones for required environmental and social due diligence documentation.
5	No	$0	$0
EXIM’s Office of Board Authorized Finance should develop a plan to ensure the Engineering & Environment Division is properly resourced to conduct the required technical reviews and environmental assessments.
6	No	$0	$0
EXIM’s Office of Board Authorized Finance should develop a written policy or procedure that outlines the process for addressing when a project’s implementation does not align with EXIM’s Environmental and Social Due Diligence Procedures and Guidelines after the Board has approved the transaction.
7	No	$0	$0
EXIM’s Office of Board Authorized Finance should develop a written policy or procedure that defines when an environmental and/or social due diligence review is necessary for any restructuring or modifications requiring Board re-approval.