AIIB’s Policy on Prohibited Practices establishes a two-tier sanctions system that consists of the Sanctions Officer and the Sanctions Panel.

The Sanctions Panel is responsible for reviewing Appeals submitted by Respondents that have been sanctioned by AIIB’s Sanctions Officer. It is composed of an external Chairperson, an external Member and an internal Member who are appointed by the AIIB President.

AIIB’s Sanctions Panel members act independently and do not answer to, or take instructions from the President, Management, the Board of Directors, representatives from AIIB Members or any other entity or individual. The decisions of the Sanctions Panel are final and cannot be appealed any further.

The Sanctions Panel is supported by a Sanctions Panel Secretary, who is appointed by the AIIB President. The Sanctions Panel Secretary is responsible for coordinating the activities of the Sanctions Panel in coordination with the Chair of the Sanctions Panel.

Enery Quinones

Enery Quinones

Chair of the Sanctions Panel (External)

Quinones was appointed by the AIIB President as Chair of the Sanctions Panel in November 2019. Her term expires in November 2025.

Quinones was a former Chair of the Nordic Investment Bank’s Sanctions Panel. From 2004 to 2014, she was the Chief Compliance Officer at the European Bank for Reconstruction and Development (EBRD). Prior to joining EBRD, Quinones was Head of the Organisation for Economic Co-operation and Development (OECD) Anti-Corruption Division. Having played a key role in developing the OECD’s anti-bribery instruments, she then developed and oversaw the implementation of the first international mechanism to monitor compliance among States Parties to the Anti-Bribery Convention. Quinones has a JD from Harvard Law School.

Shoaib Suddle

Shoaib Suddle

Member of the Sanctions Panel (External)

Suddle was appointed by the AIIB President as the External Member of the Sanctions Panel in November 2019. His term expires in May 2025.

Suddle was the Federal Tax Ombudsman of Pakistan. He began his police career in 1973 and has held several key positions, both at operational and strategic levels. He headed two provincial police departments as Inspector General Police (Balochistan and Sindh respectively). In recognition of his exceptional contributions, he was decorated with the top civil award in 2008 by the Government of Pakistan. Suddle has a PhD in white-collar crime from Cardiff University and an LLB from the University of the Punjab.

Nicolette De Witt

Nicolette De Witt

Member of the Sanctions Panel (Internal)

De Witt was appointed by the AIIB President as the Internal Member of the Sanctions Panel in November 2019. Her term expires in November 2025.

De Witt served as an operational policy advisor and operational lawyer at the World Bank for over three decades until her retirement in 2014. During her tenure, she served as Legal Policy Advisor to the Board’s Committee on Development Effectiveness, as well as advisor to member country clients and staff on the World Bank’s operational policies and operations. She also led several exercises to modernize these policies and the World Bank’s legal documentation. Since 2015, De Witt has served as a senior legal consultant to AIIB. De Witt received her JD from Harvard Law School and her BA from the University of Chicago. Prior to joining the World Bank, she served as a law clerk in the US Federal District Court of New Jersey and worked as an associate attorney in New York and Tokyo.

Nicolette De Witt

Lena Bodner

Sanctions Panel Secretary

Bodner was appointed by the AIIB President as the Sanctions Panel Secretary in January 2023. Her term expires in November 2025.

Bodner is concurrently a Secretariat officer in AIIB since 2020. She previously worked with the European Bank for Reconstruction and Development. Bodner received her Master’s in International Political Economy from King’s College London in the United Kingdom.



For additional information on Integrity at AIIB, please visit: Frequently Asked Questions on Integrity.

To contact the Sanctions Panel, please email sanctionspanel@aiib.org.