Accountability Counsel and the Center for International Environmental Law (“CIEL”) submit the following comments for consideration in the Palm Oil Sector Strategy Review. Our organizations are based in the United States and work on behalf of communities impacted by the World Bank Group’s policies and practices around the world. In particular, Accountability Counsel works with the Papua New Guinea-based organization Centre for Environmental Law and Community Rights (“CELCOR”) in their complaint to the World Bank Inspection Panel on behalf of smallholders opposed to the World Bank’s Smallholder Agricultural Development Project.1 That complaint was found eligible and an Inspection Panel investigation is proceeding. We offer the following comments based on this work, a study of other World Bank Group palm oil projects, and a review of the World Bank Group’s draft Framework for Engagement in the Palm Oil Sector (“Draft Framework”).