2019: The Year That Was

The Asian Infrastructure Investment Bank (AIIB) entered its fifth year of operations in 2020, the last of our start-up phase. Here’s a summary of the year that was.
Strength in Members
On June 29, 2015, representatives from 37 regional and 20 nonregional members gathered for the signing ceremony of the Articles of Agreement that form the legal basis of our existence. Those first 57 are our founding members. We began operations on Jan. 16, 2016, and on July 13, 2019 we reached the milestone membership number of 100 as we welcomed three nonregional countries (Benin, Djibouti and Rwanda) as prospective members. By the end of 2019, we breached the 100-mark with 102 approved members (76 members plus 26 prospective members). We ended the year with projects in 21 of our 102 members, all of which are our partners in pursuit of our mission.

Approved Members *
  • YEAR
  • TOTAL***
  • End-2019
  • 102 Total
    (aggregated, members and prospective members)
    % Change

    2017 10%
    2017 21%
    2016 79%
  • End-2018
  • 93 Total
    (aggregated, members and prospective members)
    % Change

    2017 11%
    2016 63%
  • End-2017
  • 84 Total
    (aggregated, members and prospective members)
    % Change

    2016 47%
  • End-2016
  • 57
  • 50 Regional

    (out of total for the indicated year)
    % Change

    2018 -
    2017 4%
    2016 35%
  • 52 Nonregional

    (out of total for the indicated year)
    % Change

    2018 21%
    2017 44%
    2016 160%
  • 21 Borrowing Members

    (out of total for the indicated year)
    % Change

    2018 62%
    2017 75%
    2016 200%
  • 50 Regional

    (out of total for the indicated year)
    % Change

    2017 4%
    2016 35%
  • 43 Nonregional

    (out of total for the indicated year)
    % Change

    2017 19%
    2016 115%
  • 13 Borrowing Members

    (out of total for the indicated year)
    % Change

    2017 8%
    2016 86%
  • 48 Regional

    (out of total for the indicated year)
    % Change

    2016 30%
  • 36 Nonregional

    (out of total for the indicated year)
    % Change

    2016 80%
  • 12 Borrowing Members

    (out of total for the indicated year)
    % Change

    2016 71%
  • 37
  • 20
  • 7
Click to generate chart
* Cumulative year-end figures. "Borrowing Members” are Members with approved loans from AIIB.

*** Aggregated, members and prospective members
Strength in Numbers

Related Topics

Our investment figures from 2016-2019

Four years after we began operations, our financial position remains stable. Our members offer strong support as displayed by our global and diversified shareholder base. They represent approximately 79 percent of the world’s population and 65 percent of global gross domestic product. We have USD100 billion in capital stock, 20 percent of which is assigned to paid-in capital. We have one of the largest paid-in capital bases of any multilateral development bank (MDB) and hold considerable liquidity over and above policy needs. By the end of 2019, we had invested USD12.04 billion in various types of infrastructure that help improve people’s lives today and will catalyze economic opportunities for future generations.
Strong Credit Position
From Our Board of Directors
Our prudent risk management and financial policies allowed us to maintain our triple-A ratings from 2017 to 2019, with a stable outlook from the top three credit rating agencies—Standard & Poor’s, Moody’s and Fitch. This enabled the success of our inaugural bond in May 2019, raising USD2.5 billion that will be invested in infrastructure. That same year, our debut bond was declared the “SSAR Bond of the Year” by the International Financing Review, the “Supranational Dollar Bond of the Year” by Global Capital, “Best SSA Bond” by Global Capital Asia and “Sustainable Finance, China, Best New Bond” by The Asset.

2019 marked the first step in our funding strategy. By participating in capital markets, we can harness further financial support from a global investor base.

On the environmental, social and governance (ESG) front, we have been rated (on an unsolicited basis) by three ESG rating agencies—ISS ESG, Sustainalytics and Vigeo Eiris. ESG refers to the three main factors in measuring an investment’s sustainability and societal impact, and these ratings are solicited by investors to enable them to determine the ESG risks of their investments.
High Financial Reporting Standards
We remain committed to the highest standards of financial and corporate governance, with responsibilities and related controls throughout the Bank being properly defined and delineated.

Our Management is responsible for establishing, implementing and maintaining effective internal controls over financial reporting (ICFR) for presentation and measurement in conformity with international financial reporting standards. Our internal control system contains monitoring mechanisms, and actions are taken to correct deficiencies identified. On June 3, 2019, our Directive on Internal Control over Financial Reporting was released, establishing a framework for the design, implementation, maintenance, testing and reporting of AIIB’s ICFR. We believe that ICFR supports the integrity and reliability of our financial statements.

By end-2019, our external auditor, PricewaterhouseCoopers, certified Management’s assessment that AIIB has maintained effective internal controls over financial reporting in accordance with the integrated framework issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).

Our COSO/ICFR implementation journey started in 2018, and since then we have been establishing our framework (planning, designing and implementing the Risk Control Matrix and control testing). Our control review and redesign are carried out by a newly established Internal Control Unit under the Office of the Controller, working with various stakeholders and other lines of defense in AIIB to ensure that controls are effectively carried out and monitored.
Risk Governance
We adhere to sound banking principles, and our strong risk governance and balance sheet helped us maintain our credit ratings for the third straight year.

We ensure that risk-taking activities are in line with our strategy and risk appetite and cover all material risk categories applicable to AIIB. To manage risk effectively, we’re building and reinforcing our risk culture, articulating and monitoring adherence to the risk appetite and leveraging a model with three lines of defense to strengthen our risk management architecture.

Our Board of Directors supported the Bank’s latest risk appetite statement and approved the top-down allocation of risk. The Board approved our updated Financial and Risk Management Policy Framework and Risk Management Framework. Special focus was given to build the foundation to manage compliance risk including anti-money laundering and combating the financing of terrorism. Model risk was also added to complement the Bank’s risk management architecture. Our Model Risk Management directive was introduced in 2019 to ensure models are used appropriately within the Bank in line with industry best practice. Updates have been made to existing risk directives to ensure they remain fit for AIIB’s development.

In line with the final phase of establishing AIIB’s Risk Management Framework, the Bank industrialized and digitalized its risk reporting capabilities throughout 2019. This facilitated greater risk-related analytical capabilities with further integration with the Bank’s wider platforms. The technology platform will support AIIB’s future growth, both in business volumes and product offerings. The improvements will also enable Senior Management to be readily informed of AIIB’s risk profile and ensure appropriate decision making.

We also began establishing the roles and responsibilities of the Bank’s workout and restructuring function. While in 2019 AIIB had no nonperforming loans, the Bank is creating the rules to ensure loan impairment preparedness. This institutes guidelines on how to recognize and deal with projects under stress, manage their recovery and resolve complex cases. Tools include early warning systems which can alert Management ahead of problems.

With our Capital Adequacy and Stress Testing Policy as a guide, we conduct stress tests to determine adherence to risk appetite limits. To communicate these activities and outcomes, we strengthened our risk-related reporting. We furthered our stress-testing capabilities in 2019 to include a greater variety of scenarios (including climate change) at both geographical and sectoral levels to ensure Management and the Board are aware of potential sources of risk.

It is also important for us to map out guidelines for the assessment, monitoring and control of the risk of legal or regulatory sanctions, financial loss or loss to reputation AIIB may suffer as a result of our failure to comply with laws, regulations, international standards and codes of conduct applicable to our banking activities. Thus, in 2019 we enhanced our minimum requirements and processes in relation to financial crime and integrity due diligence when dealing with customers and counterparties. This accelerated the implementation of our Directive on Anti-Money Laundering and Combating the Financing of Terrorism. We consolidated our due diligence databases and held training sessions to better equip responsible staff with tools to conduct preliminary screening and research to identify and mitigate counterparty risks. Moody’s supported AIIB’s Know Your Customer (KYC) and Financial Crime and Integrity assessments in 2019. As we continue to refine our procedures, even more specific guidelines on KYC and Financial Crime and Integrity Due Diligence will be issued for the Bank.
Assurance and Advisory
Our Internal Audit Office (IAO) provides professional and objective assurance and advisory services that add value to and improve our operations. Internal audit’s mission is to enhance and protect organizational value by providing risk-based and objective assurance, advice and insight. IAO helps AIIB accomplish its objectives by bringing a systematic, disciplined approach to evaluate and improve the effectiveness of governance, risk management and control processes.

IAO governs itself by adhering to the elements denoted as Mandatory Guidance in the International Professional Practices Framework of the Institute of Internal Auditors, including the Core Principles for the Professional Practice of Internal Auditing, the Code of Ethics, the International Standards for the Professional Practice of Internal Auditing and the Definition of Internal Auditing. IAO ensures that it remains free from all conditions that threaten the ability of internal auditors to carry out their responsibilities independently and in an unbiased manner, including on matters of audit selection, scope, procedures, frequency, timing and report content.

In 2019, we envisaged a transformative internal audit function and began evolving by adopting innovative practices, reinforcing a learning culture and leveraging new technology by implementing a cloud-based audit management system. IAO’s capabilities and mindsets are continuously developed through successful implementation of the agile audit methodology.
In 2019 we implemented the Accountability Framework approved by our Board a year earlier. The framework is an update to our governance model to increase accountability, transparency and efficiency. It positions AIIB to embed a culture of accountability throughout the organization. It strengthens (1) the Board’s role in establishing AIIB’s strategies and policies; (2) the President’s role in conducting AIIB’s business, including through delegation from the Board to the President the authority to approve projects except those reserved for Board consideration and (3) the Board’s role in holding the President accountable for management of our Bank.

Our President may approve projects that fulfill predefined requirements following a transparent process and shall submit to the Board the summaries of projects based on predetermined criteria. First, the projects must have passed concept review by the Investment Committee composed of the Chief Risk Officer, Vice President for Policy and Strategy, Chief Financial Officer and is co-chaired by—beginning 2020—the Vice Presidents for Investment Operations. Second, the projects must have been determined for approval within the President’s authority. Third, any Director can call any of these projects into the Board of Directors if deemed necessary. This governance model was initiated in 2019, and by year-end the President had approved three projects: (1) India: Rajasthan 250 MW Solar Project—Hero Future Energies, (2) Pakistan: Karachi Bus Rapid Transit Red Line Project and (3) Bangladesh: Power System Upgrade and Expansion.

This model enhances our efficiency and increases our President’s accountability. The framework sets clearly demarcated roles and responsibilities for the Board and Management. It is in line with best modern governance practice, fit for a new MDB with a nonresident Board like AIIB.

The Bank’s governance model was further updated when the Board of Directors approved the Oversight Mechanism on July 10, 2019. The mechanism assists the Board in supervising the management and operation of the Bank on a regular basis according to the principles of transparency, openness, independence and accountability outlined in our Articles of Agreement. The Oversight Mechanism consists of (1) functions of the Complaints-resolution, Evaluation and Integrity Unit (CEIU), namely Project-related complaints, evaluation and anti-fraud and corruption; (2) the external audit function, as undertaken by the External Auditor appointed by the Board and (3) staff grievance mechanism. The Board further approved CEIU’s terms of reference; the revised terms of reference of the Board’s Audit and Risk Committee, Budget and Human Resources Committee and Policy and Strategy Committee and the revisions to the Board of Directors’ Rules of Procedure to codify CEIU’s roles and functions.
Building Partnerships and Learning Resources
The development challenge in Asia is beyond the capacity of one organization to undertake alone. There are many effective and talented organizations in the development ecosystem that have strong expertise and experience in specific modalities and sectors. AIIB’s mode of operations relies on the Bank working in partnership with these like-minded private and public sector actors to maximize the use of scarce resources, avoid duplication of efforts and learn efficiently.

One such partnership involves adapting to or mitigating the effects of climate change. In September 2019 at the UN Secretary-General’s Climate Action Summit in New York, we joined eight other MDBs in an agreement to increase the global climate action investments we support together each year to USD175 billion by 2025. MDB climate finance in developing countries and emerging economies in 2018 reached record annual levels, resulting in USD111 billion of combined MDB climate finance and cofinance. We jointly agreed to increase those investments.

Related Topics

How our 2019 projects align with the SDGs

When it comes to being effective and efficient with resources, strong governance and avoiding corruption is an important way to protect funds dedicated to development outcomes. In line with our “Clean” core value, we have joined networks of individual professionals and organizations who strive to maintain the highest standards in ethics and accountability in their operations.

AIIB continues to collaborate closely with other MDBs in fighting corruption. We foster exchange of information and closer working contacts through the MDB Heads of Integrity Meeting and the Conference of International Investigators. We are formalizing our collaboration through Memorandums of Understanding, including this year with ADB’s Office of Integrity and Anticorruption.

AIIB’s membership in the Ethics Network of Multilateral Organizations (ENMO) was approved in July 2019, demonstrating our commitment to the same high standards. ENMO brings together senior professionals responsible for the ethics functions in multilateral intergovernmental institutions to exchange information and experience and collaborate on issues of common interest. We look forward to working with other ENMO members to share best practices and explore possibilities for cross-institutional collaboration.

Moreover, we furthered our internal accountability learnings by networking externally. We have been actively doing this since becoming an institutional member of the Independent Accountability Mechanisms Network (IAMnet) in April 2019. IAMnet is a network of practitioners that regularly shares ideas and assist with institutional capacity building in accountability and compliance as components of corporate governance. We participated in IAMnet outreach activities and network meetings, and CEIU represented AIIB at the annual IAMnet meeting hosted by the African Development Bank in June 2019.

AIIB also became an institutional member of the Global Delivery Initiative (GDI) in April 2019. GDI is a partnership of over 50 development organizations focused on collecting and sharing operational insights and lessons to better understand what works—and doesn’t—in project implementation. GDI specialists made two virtual presentations to interested AIIB staff.

In July 2019, we signed a partnership memorandum with the International Fund for Agricultural Development (IFAD)—a specialized agency of the United Nations—for cofinancing projects and programs, mobilizing private sector financing and for research and analysis. IFAD has a strong focus on the development of rural infrastructure, renewable energy sources and climate change adaptation and mitigation.

We also signed an agreement with the European Stability Mechanism (ESM) in July 2019 to establish a framework for greater collaboration. The framework covers technical cooperation, exchange on economic and policy strategy, funding, risk management, corporate governance, legal services and the secondment of staff. ESM’s support for AIIB goes back to 2017 when they assisted us in setting up our SWIFT infrastructure. This allowed AIIB to communicate securely and efficiently with financial institutions across the globe.

To further our mandate, partnerships with private financial institutions were also necessary.

In July 2019, we forged a strategic partnership with Aberdeen Standard Investments to develop sustainable debt capital markets for infrastructure, drive responsible investing in fixed income and build an effective ESG ecosystem in emerging markets in Asia.

In September 2019, we partnered with Amundi for a USD500-million Asia Climate Bond Portfolio which aims to address the underdevelopment of the climate bond market. Amundi is Europe’s largest asset manager by assets under management and ranks in the global top 10. Our collaboration shows how MDBs and the private sector can jointly accelerate climate action in our members.

In November 2019, we established Bayfront Infrastructure Management Pte. Ltd. (BIM) with Clifford Capital Pte. Ltd. BIM is a first-of-its-kind platform designed to mobilize a new pool of institutional capital and address the infrastructure financing gap in Asia.

As we have from the outset, we continue to cofinance within the family of MDBs. In March 2019, we entered into a comprehensive Cofinancing Framework Agreement for sovereign operations with the Asian Development Bank (ADB). In the same year, we cofinanced projects with the International Finance Corporation, the International Development Association, ADB, the European Bank for Reconstruction and Development, the Black Sea Trade and Development Bank and the Eurasian Development Bank.

Human Resources, Training and Development

We consider our staff to be our most valuable resource. With “Lean” as one of our core values, we’re conscious not only of our growth in terms of numbers, but also our growth as individuals and as a collective. Staff capacity, competency and capability are of high importance for us as we end our start-up phase and prepare for the decades to come.

Having a diverse workforce helps us better understand our clients and members. As we continue to grow in numbers, we’re also keen to recruit the right talent from around the world. By end-2019, we had grown to a mix of 50 nationalities (up from 44 in 2018). In addition, we closed the year with women comprising 39 percent of our staff (up from 32 percent in 2018).
Staff *
  • YEAR
  • End-2019
  • 279 Total Professional Staff Count

    % Change

    2018 50%
    2017 113%
    2016 253%
  • End-2018
  • 186 Total Professional Staff Count

    % Change

    2017 42%
    2016 135%
  • End-2017
  • 131 Total Professional Staff Count

    % Change

    2016 66%
  • End-2016
  • 79
  • 108 (39% of total) Female Professional Staff

    % Change

    2018 83%
    2017 157%
    2016 500%
  • 50 Nationalities Represented

    % Change

    2018 14%
    2017 39%
    2016 117%
  • 59 (32% of total) Female Professional Staff

    % Change

    2017 40%
    2016 228%
  • 44 Nationalities Represented

    % Change

    2017 22%
    2016 91%
  • 42 (32% of total) Female Professional Staff

    % Change

    2016 133%
  • 36 Nationalities Represented

    % Change

    2016 57%
  • 18 (23% of total)
  • 23
Click to generate chart
* Cumulative year-end figures.
We continue to hone our human resources. We believe a good mix of individual and team training will lead to better staff performance and, ultimately, better client service.

One such training is our Operational Training Program. It is a four-day modular training on core AIIB operational topics about our project cycle, safeguards and fiduciary matters. The objectives are to increase staff knowledge and expertise in AIIB’s operations and mitigate operational risks.

We also launched our Credit and Investment Program in 2019, a three-week intensive program designed to standardize the credit and investment approach of staff in investment operations and risk management. This program helps us continuously deliver high-quality client services and better align staff operations with AIIB’s strategic vision and policy framework.

Then there was our Workshop on Project Economic Analysis for staff members. Participants gained knowledge on sovereign and nonsovereign project economic analysis along with lessons learned in the past four years. We want to ensure that best practices are codified, reflected upon and implemented moving forward.

From Our Board of Directors
Staff also bolstered their knowledge through the Investment Operations Sovereign Finance Training, aimed at facilitating understanding of the legal aspects of sovereign-backed projects. The interactive training was useful not only for aspiring project team leaders, but also for other staff involved in project work in different capacities.

In 2019, we offered time management courses to equip our staff with tools, anchors and mindset reframes designed to better deal with competing demands on their schedules and attention. This allows staff to deepen their abilities, perform at high standards and stay client-oriented while maintaining work-life balance and avoiding burnout.

Learning never ends. Our Senior Management Team, Directors General and Managers began attending a 12-month Leadership and Management Skills Program that entails face-to-face training focused on the self, the team and organizational leadership as well as executive coaching. This leadership journey aims to align AIIB’s Senior Management Team and give them the necessary skills, knowledge and tools to effectively lead our Bank.

A suite of soft skills training is currently being developed and will be launched in 2020. Staff development will emphasize on-the-job learning and sharing best practice distilled from operational experience. We will continue to encourage leadership development and managerial accountability by strongly adhering to leadership principles, including through recruitment and performance management.

We will strengthen our talent management system to attract, recruit, incentivize and retain high-performing staff. Having a mindset steeped in growth, collaboration and teamwork will enable our team to deliver the impact our clients and members expect. It will help us grow and retain talent. It will help us position AIIB as an employer of choice.

Corporate Culture

From Our Board of Directors
We can only be successful if we establish the right corporate culture—one that is professional, responsive and accountable. The concept of “Lean” will remain core to our corporate culture, eliminating waste in production and processes and delivering more value for clients and shareholders. This culture will be fostered to ensure we attract and retain the staff we need.

Over 70 staff volunteers have translated our cultural attributes into concrete bottom-up programs such as idea creation, innovation, peer-to-peer recognition, diversity and inclusivity, among others. We are creating a corporate culture that will underpin our objective to become a 21st century MDB characterized by fast and responsive client services, innovative and efficient practices, good governance and accountability. We aim to be recognized as an institution responding effectively to client demands while maintaining high international standards. We strive to be both a preferred partner for infrastructure clients and investors and an employer of choice for top professionals with the right talents.

We intend to deliver maximum impact with the highest possible efficiency, especially with respect to project preparation and delivery. To this end, we will continue to study and learn from the management styles and decision-making processes of other high-performing public and private financial institutions.

We will invest in our internal technology—including in data analytics—to enable more efficient procedures, effective client relationship management and informed decision-making. We will also embrace technology and develop it as our comparative advantage and core value proposition for clients.

The socialization of our cultural attributes and our corporate culture objectives is part of onboarding new staff, giving new members of the AIIB team a clear path to success in our organization.

Our Core Values

We are an agile organization that strives to eliminate waste in production and processes while satisfying customer needs. Continuous improvement will remain central to our value proposition and ambition to deliver more value to clients through fast and responsive services without compromising high standards. This requires purposeful procedures, effective systems, leveraging partnerships, the ability to quickly redeploy resources and an institutional culture which prioritizes continuous improvement, efficiency and the best possible service to clients.

We hold ourselves to the highest standards in everything we do. High project standards and good governance principles constitute an integral part of our Clean core value. Our governance structure underpins an unwavering commitment to integrity, accountability and ethical standards in our projects and the way we work with clients and partners. We have zero tolerance for corruption. We have institutionalized measures to protect whistleblowers who report prohibited practices in projects. We promote transparency through a policy on disclosure of information.

We embrace the concept of being a green institution and are committed to enhancing our sustainable operations both in terms of project investments and corporate practices. Our policies, strategies and operations are aligned around promoting green objectives. We aspire to play a leading role in mainstreaming green objectives in the Asian financial and capital markets. We hold ourselves to high international standards through our Environmental and Social Framework which integrates environmental and social management methods into all of our operations. Our green objectives involve a special focus on climate mitigation and adaptation at the member or regional level through our projects. We embrace Green in our corporate practices and take concrete action to manage our own carbon footprint.

Our Governance

Growth is based on good governance.
Board of Governors
From Our Board of Directors
All our powers are vested in the Board of Governors (BOG), where each AIIB member is represented by a Governor and an Alternate Governor, both of whom serve at the pleasure of the appointing member. At each of its annual meetings, the BOG elects one of the Governors as chair who holds office until the election of the next chair.

The BOG has the power to, among others, admit new members and determine the conditions of their admission, suspend a member, increase or decrease our authorized capital stock, elect our Directors, elect our President or suspend or remove the President from office.

The BOG has delegated a broad range of operational oversight functions to the Board of Directors.
Board of Directors
Our 12-member Board of Directors (BOD), elected by the Governors, is responsible for the strategic direction of our general operations, including setting our policies and strategies and overseeing their implementation.

The BOD functions on a nonresident basis in line with our lean culture, exercising all powers delegated to it by the BOG. The BOD meets as often as business requires—both through physical meetings and by videoconference—and maintains regular communication with our management between meetings. Under the direction of the BOD and as its chair, the President conducts the Bank’s business and is held responsible and accountable for our effective and efficient day-to-day operations.

In 2019, the BOD met physically four times, with an equal number of virtual meetings in the same year.

The BOD’s Oversight Mechanism helps the Board supervise AIIB’s management and operations on a regular basis. CEIU which is part of the Oversight Mechanism is headed by a Managing Director who reports directly to the Board.
Board Committees
To ensure that we perform our mandate based on sound strategies and practices, three committees under the BOD give us guidance. These are the Audit and Risk Committee (ARC), the Budget and Human Resources Committee (BHRC) and the Policy and Strategy Committee (PSC).

The ARC assesses our financial statements, reporting practices, procedures and issues and reviews reports from the external auditors. Meanwhile, the BHRC assesses the proposed annual budget and implementation of our compensation and benefits policies. This committee also considers any other aspects of the budget and our human resources as the BOD may request. Finally, the PSC reviews our financial and operational policies (such as environment, social and procurement policies) and advises us on the development of our strategies.

In 2019, the BOD committees met physically four times, with three virtual meetings in the same year.
Senior Management
Staff are headed by our President who is elected by AIIB shareholders for a five-year term and is eligible for reelection once. In 2019, the President was supported by our Senior Management which includes our Vice Presidents (responsible for policy and strategy, investment operations, finance, administration and the corporate secretariat), the General Counsel, the Chief Risk Officer and the Chief Programming Officer. In 2020, the amended Terms of Reference of the Executive Committee lists key AIIB management personnel as the President, the Vice Presidents, the General Counsel, the Chief Risk Officer and the Chief Financial Officer. Together they comprise our most senior management body.
Expert External Advice
We have an International Advisory Panel (IAP) that supports the President and Senior Management on our strategies, policies and general operations. The panel meets at least twice a year—at our Annual Meeting and at our headquarters. The President appoints IAP members to an initial two-year term which can be renewed upon completion. Panelists receive a small honorarium and do not receive a salary.
Sanctions Panel
The President appointed three members to the Bank’s first Sanctions Panel in November 2019. As an independent function within the Bank, the panel reviews appeal of sanctions imposed by the Sanctions Officer pursuant to the Policy on Prohibited Practices. Decisions of the panel are final and cannot be appealed.