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.

Bernard O’Donnell

Bernard O’Donnell

Member of the Sanctions Panel (External)

O’Donnell was appointed by the AIIB President as the External Member of the Sanctions Panel in June 2025. His term expires in December 2027.

Bernard O’Donnell has worked in the field of investigations for over 40 years, most recently as the Head of Investigations at the European Investment Bank. Previously, he was the Head of Investigations for the United Nations Development Programme in New York, USA, where he played a key role in developing UNDP’s vendor review (sanctions) mechanism. As the first appointed Head of Investigations for the Global Fund to Fight Aids, Tuberculosis and Malaria in Geneva, Switzerland, he established the investigations capability and oversaw investigation globally. O’Donnell holds a master’s degree in law from De Montfort University, England, United Kingdom.

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.

Stefanie Chan

Stefanie Chan

Sanctions Panel Secretary

Chan was appointed by the AIIB President as the Sanctions Panel Secretary in August 2025.

Philip Daltrop

Philip Daltrop

Member, Reserved Roster of Temporary External Panel Members

Philip Daltrop was appointed by the AIIB President as a Member of the Reserved Roster of Temporary External Panel Members in August 2025. His term expires in August 2030.

Daltrop is the current chair of the World Bank Group Sanctions Board, having joined the Board in 2022. He spent 20 years with the Asian Development Bank (ADB) in Manila, where he was Deputy General Counsel and also headed ADB’s procurement, integrity and internal audit offices. Earlier in his career, he worked for a leading international law firm and as a lawyer for the UK Foreign Office, the Inter-American Development Bank and the World Bank. He holds degrees in Philosophy, Politics and Economics, and in International Human Rights Law, from the University of Oxford.

Mahnaz Malik

Mahnaz Malik

Member, Reserved Roster of Temporary External Panel Members

Mahnaz Malik was appointed by the AIIB President as a Member of the Reserved Roster of Temporary External Panel Members in August 2025. Her term expires in August 2030.

Ms. Malik practices as an Arbitrator and Barrister from Twenty Essex Chambers in London. She has over 25 years of legal experience in cross-border trade and investment, including serving as an arbitrator in commercial and investment law matters, acting as counsel to investors, companies and states, and working as a consultant to international organizations. Malik is a Fellow and Trustee of Hughes Hall College, University of Cambridge. She has served as a member of the Panel of Arbitrators of the International Centre for Settlement of Investment Disputes (ICSID) for over a decade, and was appointed as a member of the ICSID ad hoc Annulment Committee in two cases. She serves as a Member of the World Bank Group Sanctions Board.

Stephen Zimmermann

Stephen Zimmermann

Member, Reserved Roster of Temporary External Panel Members

Stephen Zimmermann was appointed by the AIIB President as a Member of the Reserved Roster of Temporary External Panel Members in August 2025. His term expires in August 2030.

Zimmermann is the Director of Internal Audit and Investigations at the United Nations Children’s Fund (UNICEF), where he oversees multi-disciplinary teams responsible for assurance and advisory services, as well as investigations into fraud, corruption and misconduct across UNICEF’s global operations. Previously, Zimmermann served as Senior Adviser to the Governance Global Practice of the World Bank, where he helped guide the Bank’s work on anti-corruption, justice and the rule of law. Prior to that, he was the Director of Operations for the Integrity Vice Presidency of the World Bank, where he oversaw teams charged with detecting, investigating, sanctioning and preventing fraud and corruption in Bank-financed activities worldwide. Zimmermann played a leading role in developing the World Bank’s integrity agenda and led efforts to reach the historic Cross-Debarment Agreement, enabling mutual enforcement of sanctions decisions by multilateral development banks. He was also the first Chief of the Office of Institutional Integrity at the Inter-American Development Bank and served as the Interim Chief of Staff for the Independent Inquiry Committee into the United Nations Oil-for-Food Programme. Earlier in his career, Zimmermann was an Assistant United States Attorney as well as a lawyer in private practice.



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

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