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.
Sanctions Panel
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:
Jelena Madir
Ms Jelena Madir is the Chief Compliance Officer at the European Bank for Reconstruction and Development (EBRD) in London. Prior to this appointment, Ms Madir was the General Counsel of Gavi, the Vaccine Alliance. Before joining Gavi in 2019, she spent nearly 11 years at EBRD, where she worked as a transactional lawyer; headed the Financial Law Unit – a unit focused on regulatory reforms in the areas of corporate governance, FinTech, insolvency and access to finance; and was also seconded to the Office of the Chief Compliance Officer and the Bank of England. Previously, Ms Madir worked as a finance lawyer for several US law firms in Washington, DC, Frankfurt and Zagreb. 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.
Rohil Hafeez
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.
