About Nefco’s sanctions process
A sanction can be, inter alia, a written reprimand, a decision that an individual or entity is ineligible, permanently or for period of time, from any form of Nefco financing (debarment), or reimbursement of funds. For more information on sanctions and remedies, please refer to Nefco’s Policy on Anticorruption and Compliance, section 6.
Decisions on sanctions are made by Nefco’s Sanctions Panel, which consists of Nefco’s Managing Director, a senior Nefco staff member and an external expert. Nefco’s Board of Directors has appointed three senior staff members and two external experts who will serve on the Sanctions Panel on a rotating basis.
In September 2021, the Board of Directors appointed the following two external experts:
Ms Jelena Madir is the General Counsel of Gavi, the Vaccine Alliance in Geneva, and is also a member of Gavi’s Executive Team. Prior to joining Gavi in November 2019, she spent nearly 11 years at the European Bank for Reconstruction and Development (EBRD) in London, where she was strongly involved in EBRD’s sanctions policies and procedures, including as the Secretary to EBRD’s Enforcement Committee. Ms Madir has a strong track record in FinTech, compliance and sanctions issues and has been member of a number of boards. She has published a book titled Sanctions Regimes of Multilateral Development Banks.
Mr Rohil Hafeez is a Chartered Accountant and an experienced IFI executive with broad experience in financial operations, risk management and adjudication. He has been Chief Risk Officer and the manager responsible for sponsor integrity due diligence at IFC, and held various positions in the World Bank Group and Deloitte. Mr Hafeez is also member of the sanctions panel of the Nordic Investment Bank and a senior advisor to the Asian Infrastructure Investment Bank.
Decisions by the Sanctions Panel to impose a sanction can be appealed to an Appeals Panel.
The sanctions process is administrative in nature.