GFO Issue 468, Article Number: 4
ABSTRACT
This article is a brief summary of the sanctions panel annual report which was presented for the 29th ethics and governance committee meeting held on 6–7 October 2025 in Geneva.
As the Global Fund’s sanctions panel enters its eleventh year of operation, its role as a key guardian of integrity and accountability continues to expand. The Global Fund’s sanctions panel was established in 2013 and it was operational since 2014. The panel has become one of the institution’s most important instruments to deter and address supplier misconduct.
Ensuring accountability in procurement and supply chains
The Global Fund relies on a network of suppliers and implementing partners across more than 100 countries. In order to protect program resources and ensure that lifesaving commodities reach communities in need, the organization has enforced strict compliance with its code of conduct for suppliers.
Cases involving serious or complex breaches of this code are referred to the sanctions panel. The sanctions panel is composed of six members, including three independent experts and three senior Global Fund managers. They review each case and recommend sanctions to the Executive Director. These sanctions can include permanent or temporary ineligibility or, in certain cases, the implementation of compliance programs to rehabilitate suppliers.
Over the past decade, the sanctions panel’s decisions have affected more than 80 individuals and entities worldwide, from major multinational corporations to small local firms. According to the 2025 report, “the sanctions panel remains a cornerstone of the Global Fund’s commitment to ethical operations and prudent stewardship of donor resources.”
A diverse and experienced leadership
The sanctions panel’s independent members bring decades of legal, regulatory, and compliance expertise from global institutions.
- Patricia Diaz Dennis (Chair) is a seasoned U.S. lawyer and former presidential appointee, Ms. Dennis has held leadership roles at AT&T and the U.S. Department of State. She previously served on the World Bank’s sanctions board.
- A. Michael Stevens is a governance and integrity specialist who established the Asian Development Bank’s integrity function and has served in senior roles in U.S. federal agencies.
- Professor Nassib G. Ziadé is a leading international jurist and arbitrator, currently chief executive officer of the Bahrain chamber for dispute resolution and president of the IMF administrative tribunal.
Their appointments are being overseen by the Global Fund’s Ethics and Governance Committee (EGC). These appointments are for two-year renewable terms. In early 2024, the EGC renewed the mandates of Mr. Stevens and Professor Ziadé until 2026, while Ms. Dennis was reappointed as chair later that year.
Adapting to an evolving integrity landscape
The 2025 report highlights a period of reflection and reform. After a pause of several years with no new cases, the Panel has received two referrals in 2025 following Office of the Inspector General (OIG) investigations. Review of both cases is expected by year’s end.
Meanwhile, the legal and governance department, working closely with the panel and OIG, is assessing opportunities to strengthen existing procedures. This review includes aligning the Global Fund’s sanctions processes with emerging best practices from peer institutions such as development banks and multilateral agencies.
Among the issues under consideration are:
- The discretionary power of the Executive Director to refer cases and accept panel recommendations;
- The distinctive Global Fund practice of publishing OIG investigation reports in full; and
- The need to clarify the role and expectations of independent members as policy reforms advance.
According to the report, these discussions could lead to “a refined operational model that better balances transparency, due process, and efficiency.”
Protecting the Global Fund’s mission
Unlike many institutions, the Global Fund operates through country-led models, where national stakeholders oversee procurement and grant implementation. This structure requires a nuanced approach to sanctions: one that deters misconduct without disrupting essential health programs.
Sanctions are therefore implemented through formal communication with country coordinating mechanisms (CCM) and principal recipients, ensuring that barred entities are excluded from Global Fund-financed activities while allowing country programs to continue serving patients.
The sanctions panel’s 2025 report reaffirms that “effective enforcement is not only about punishment it is about preserving trust, safeguarding health impact, and upholding the values that underpin every grant.”
Looking ahead
The EGC will revisit the panel’s composition in 2026, when Ms. Dennis’s term as Chair concludes. At that time, members will consider whether to reappoint current independent experts or launch a new selection process.
In parallel, updates to the sanctions panel procedures and related OIG policies are expected in 2026, ensuring continued alignment with international standards.
As the Global Fund continues its mission to end AIDS, tuberculosis, and malaria, the sanctions panel stands as a reminder that strong governance and ethical vigilance are indispensable foundations for achieving global health equity.
“Integrity is not an administrative function it is a moral obligation,” said Chair Patricia Diaz Dennis. “Every sanction we recommend protects the trust that millions of people place in the Global Fund every day.”
As the Global Fund’s sanctions panel enters its eleventh year of operation, its role as a key guardian of integrity and accountability continues to expand. The Global Fund’s sanctions panel was established in 2013 and it was operational since 2014. The panel has become one of the institution’s most important instruments to deter and address supplier misconduct.
Ensuring accountability in procurement and supply chains
The Global Fund relies on a network of suppliers and implementing partners across more than 100 countries. In order to protect program resources and ensure that lifesaving commodities reach communities in need, the organization has enforced strict compliance with its code of conduct for suppliers.
Cases involving serious or complex breaches of this code are referred to the sanctions panel. The sanctions panel is composed of six members, including three independent experts and three senior Global Fund managers. They review each case and recommend sanctions to the Executive Director. These sanctions can include permanent or temporary ineligibility or, in certain cases, the implementation of compliance programs to rehabilitate suppliers.
Over the past decade, the sanctions panel’s decisions have affected more than 80 individuals and entities worldwide, from major multinational corporations to small local firms. According to the 2025 report, “the sanctions panel remains a cornerstone of the Global Fund’s commitment to ethical operations and prudent stewardship of donor resources.”
A diverse and experienced leadership
The sanctions panel’s independent members bring decades of legal, regulatory, and compliance expertise from global institutions.
- Patricia Diaz Dennis (Chair) is a seasoned U.S. lawyer and former presidential appointee, Ms. Dennis has held leadership roles at AT&T and the U.S. Department of State. She previously served on the World Bank’s sanctions board.
- A. Michael Stevens is a governance and integrity specialist who established the Asian Development Bank’s integrity function and has served in senior roles in U.S. federal agencies.
- Professor Nassib G. Ziadé is a leading international jurist and arbitrator, currently chief executive officer of the Bahrain chamber for dispute resolution and president of the IMF administrative tribunal.
Their appointments are being overseen by the Global Fund’s Ethics and Governance Committee (EGC). These appointments are for two-year renewable terms. In early 2024, the EGC renewed the mandates of Mr. Stevens and Professor Ziadé until 2026, while Ms. Dennis was reappointed as chair later that year.
Adapting to an evolving integrity landscape
The 2025 report highlights a period of reflection and reform. After a pause of several years with no new cases, the Panel has received two referrals in 2025 following Office of the Inspector General (OIG) investigations. Review of both cases is expected by year’s end.
Meanwhile, the legal and governance department, working closely with the panel and OIG, is assessing opportunities to strengthen existing procedures. This review includes aligning the Global Fund’s sanctions processes with emerging best practices from peer institutions such as development banks and multilateral agencies.
Among the issues under consideration are:
- The discretionary power of the Executive Director to refer cases and accept panel recommendations;
- The distinctive Global Fund practice of publishing OIG investigation reports in full; and
- The need to clarify the role and expectations of independent members as policy reforms advance.
According to the report, these discussions could lead to “a refined operational model that better balances transparency, due process, and efficiency.”
Protecting the Global Fund’s mission
Unlike many institutions, the Global Fund operates through country-led models, where national stakeholders oversee procurement and grant implementation. This structure requires a nuanced approach to sanctions: one that deters misconduct without disrupting essential health programs.
Sanctions are therefore implemented through formal communication with country coordinating mechanisms (CCM) and principal recipients, ensuring that barred entities are excluded from Global Fund-financed activities while allowing country programs to continue serving patients.
The sanctions panel’s 2025 report reaffirms that “effective enforcement is not only about punishment it is about preserving trust, safeguarding health impact, and upholding the values that underpin every grant.”
Looking ahead
The EGC will revisit the panel’s composition in 2026, when Ms. Dennis’s term as Chair concludes. At that time, members will consider whether to reappoint current independent experts or launch a new selection process.
In parallel, updates to the sanctions panel procedures and related OIG policies are expected in 2026, ensuring continued alignment with international standards.
As the Global Fund continues its mission to end AIDS, tuberculosis, and malaria, the sanctions panel stands as a reminder that strong governance and ethical vigilance are indispensable foundations for achieving global health equity.
“Integrity is not an administrative function it is a moral obligation,” said Chair Patricia Diaz Dennis. “Every sanction we recommend protects the trust that millions of people place in the Global Fund every day.”
