新近立法和判例表明，国际借贷中的贷款人面临着清污责任的法律问题。贷款人清污责任是指政府（或其行政机关）为保护和治理环境，依法清理借款人的危险性废物造成的污染，因清理污染支出的费用，以贷款人“真正参与借款人的管理”为法定依据，责任由贷款人严格地、连带地承担。本文通过对美国立法和判例的研究，认为贷款人承担清污责任的依据是“真正参与借款人的管理”。贷款人应审视其“清污责任风险”，以担保方式的信用化和不当“影子董事”作为规避风险的主要手段。我国宜立法增设贷款人的清污责任 Recent legislation and jurisprudence show that lenders in international lending face the legal problem of responsibility for decontamination. The responsibility of the lender to clear the pollution refers to the pollution caused by the government (or its administrative organ) to clean up the borrower’s hazardous wastes in accordance with the law in order to protect and control the environment. Because the borrower “really participates in the management of the borrower” due to the pollution expenses, For the legal basis, the responsibility borne by the lender strictly and jointly. Based on the research on American legislation and precedent, this paper argues that the basis for borrower’s responsibility of removing pollution is “to truly participate in the management of the borrower.” Lenders should examine their “risk of decontamination responsibility” and take the credit guarantee and improper “shadow directors” as the main means of risk aversion. It is appropriate for our country to legislate to increase the responsibility of the lenders in clearing pollution