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.

Bernard O’Donnell

Bernard O’Donnell

Chair of the Sanctions Panel (External)

O’Donnell was appointed by the AIIB President as the External Member of the Sanctions Panel in June 2025, and then appointed as the Chair in December 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 and Inspector General ad interim. He played a leading role in the development and implementation of EIB’s Exclusion (sanctions) Policy. 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. He currently also serves as the President of the Institute for International Criminal Investigations. O’Donnell holds a master’s degree in law from De Montfort University, England, United Kingdom.

Norbert Seiler

Norbert Seiler

Member of the Sanctions Panel (External)

Seiler was appointed by the AIIB President as the External Member of the Sanctions Panel in December 2025. His term expires in December 2028.

Seiler serves as Chair of the Enforcement Appeals Committee of the Asian Development Bank, as a member of the Appeals Committee of the Organization of the Petroleum Exporting Countries (OPEC) Secretariat, and as a member of the Administrative Tribunal of the OPEC Fund for International Development. Seiler is a senior legal executive with over 40 years of professional experience, including some 30 years at the European Bank for Reconstruction and Development (EBRD). At EBRD, he advised on the development and implementation of policies safeguarding the integrity of operations and procurement processes, and he chaired both the Enforcement Committee and the Procurement Complaints Committee. He also provided legal advice on EBRD’s governance arrangements, loans, equity investments and treasury operations. Seiler holds a Doctor Juris and Magister Juris from the University of Vienna, and a Master of Comparative Jurisprudence from the School of Law, New York University.

Ian Nightingale

Ian Nightingale

Member of the Sanctions Panel (Internal)

Nightingale was appointed by the AIIB President as the Internal Member of the Sanctions Panel in December 2025. His term expires in December 2027.

Nightingale has served as Senior Procurement Adviser to AIIB since 2015, during which he developed AIIB’s Procurement Policy, approved at the Bank’s inaugural Board meeting in January 2016. He has subsequently led several exercises to modernize and update the policy, and provided guidance to AIIB Members, Bank staff, and the business community on its implementation. Before joining AIIB, he was Lead Procurement Specialist at the World Bank for six years, working both at its headquarters in Washington, D.C. and the Beijing Procurement Hub. Prior to that, he spent 11 years as Deputy Procurement Director at the European Bank for Reconstruction and Development (EBRD) in London, where he oversaw EBRD’s Procurement Policy Department and managed procurement strategy, policy compliance, and investigations of procurement-related complaints and fraud. He is a Chartered Engineer, a Member of the Institution of Mechanical Engineers and a Member of the Chartered Institute of Purchasing and Supply, United Kingdom. He holds a degree from University of Portsmouth, United Kingdom.

Stefanie Chan

Stefanie Chan

Sanctions Panel Secretary

Stefanie Chan was appointed by the AIIB President as the Sanctions Panel Secretary in August 2025. Her term expires in August 2028

Chan is a Secretariat Officer in the AIIB Corporate Secretariat, where her portfolio includes governance, supporting the Board of Directors during their regular meetings, supervising elections pertaining to the Bank and the Board, and serving as Secretary to the International Advisory Panel. She has extensive experience in governance and program management within the development and environment sectors, having most recently worked at the UN Environment Programme. Chan graduated cum laude in law from the Singapore Management University and is admitted to the Singapore Bar. She has worked in dispute resolution and intellectual property at a leading law firm in Singapore, and also served as a pro bono/corporate responsibility manager at Hogan Lovells in Paris.

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.