IFC believes that transparency and accountability are fundamental to fulfilling our development mandate and strengthening public trust in IFC and our clients. IFC’s Access to Information Policy (AIP) recognizes the right to an appeals process when a request to access information in IFC’s possession is denied.
A requester whose request to access information has been denied can file an appeal if the requester believes that the request has been unreasonably denied, or that the AIP has been interpreted incorrectly.
The AIP provides two levels of appeals: the first level appeal goes to IFC’s Access to Information Policy Advisor (AIP Advisor) and the second level appeal goes to the independent Access to Information Appeals Panel (AIP Panel). In both cases, appeals should be submitted through IFC’s Disclosure Portal.
Decisions made by the IFC Board of Executive Directors are not subject to appeal.
The sole remedy available to those who prevail in the appeals process is to receive the information requested.
Decisions of the AIP Advisor and AIP Panel issued from September 2025 onward will be made publicly available.
AIP Advisor
The AIP Advisor serves as the first stage of appeal and reports directly to IFC’s Executive Vice President. The AIP Advisor’s review focuses on whether the requested information falls within the scope of paragraph 8 of the AIP and, if so, whether IFC has a reasonable basis for determining that there is a compelling reason not to disclose such information pursuant to paragraph 10 of the AIP. The AIP Advisor’s authority does not extend to paragraph 12, the application of which is solely within IFC senior management’s discretion. The AIP Advisor will endeavor to respond to the requester within 30 calendar days of receipt of the appeal, unless additional time is required because of the scope or complexity of the appeal.
Elena Bourganskaia, IFC’s Vice President, Strategy and Operations Support, is currently serving as IFC’s AIP Advisor.
AIP Panel
The AIP Panel serves as the second stage of appeal, following a decision by the AIP Advisor to uphold IFC’s decision to deny access to the requested information. A requester may appeal to the AIP Panel within 30 calendar days of the notification of the AIP Advisor’s decision. The scope of review by the AIP Panel is limited to whether the AIP Advisor had a reasonable basis for their determination. The AIP Panel will endeavor to respond to the requester within 60 days of receipt of the appeal, unless additional time is required because of the scope or complexity of the appeal. The AIP Panel decisions are final.
The AIP Panel comprises three independent, outside experts on access to information in a commercial setting nominated by IFC’s Executive Vice President and endorsed by IFC’s Board of Directors. The AIP Panel members are appointed to serve a specific term. They are bound by IFC’s AIP and follow the AIP Panel Procedures when discharging its functions.
Ms. Kristin Brudy-Everett, a United States national, is the Senior Component Official for Privacy and Freedom of Information Act (FOIA) Officer for the U.S. Department of Justice Organized Crime Drug Enforcement Task Forces, where she oversees the division’s privacy, FOIA, and information law matters. Formerly, Ms. Brudy-Everett was an Assistant United States Attorney in the Civil Division of the United States Attorney’s Office for the District of Columbia, where she litigated information law and immigration cases. Her previous roles were with the White House Council on Environmental Quality and U.S. Department of Homeland Security, where she started as a part of the prestigious Presidential Management Fellow program.
Ms. Obioma Okonkwo, a Nigerian national, currently serves as an Advisory Board member of the Digital Democracy Initiative, an initiative funded by the Danish Ministry of Foreign Affairs, Norwegian Government, and European Union to strengthen civic engagement and promote inclusive democracy in the digital era in Global Majority. Obioma has also served as Head of Legal at Media Rights Agenda in Nigeria, where she spearheaded crucial advocacy campaigns, training programs, research initiatives, and legal proceedings focused on advancing access to information on a national, regional, and international level. From 2018 to 2021, Ms. Obioma worked as an attorney at the human rights law firm of Solomon Okedara & Co, where she deepened her expertise on human and digital rights advocacy. Her expertise has been recognized through numerous prestigious fellowships, including the International Strategy Forum, Open Internet for Democracy Leadership Program, Deutsche Welle Media Viability Ambassador Program, and the African School on Internet Governance. She holds a Bachelor of Laws (LLB) from Olabisi Onabanjo University, Nigeria, and earned her Certificate of Legal Education from the Nigerian Law School, qualifying her as an Attorney-at-law.
Mr. Stuart Rick, a United States national, has extensive experience with the U.S. Freedom of Information Act (FOIA) and was awarded by the U.S. Office of Personnel Management for his work as the agency’s final decision-maker on administrative appeals from initial denials of FOIA requests. After retiring from the U.S. Government as the Deputy General Counsel of the U.S. Office of Government Ethics, Stuart advised a Federal department on how to respond to FOIA appeals. Subsequently, for ten years Stuart was a consultant in the World Bank’s Office of Ethics and Business Conduct where he developed and implemented the Bank’s public declaration of interests program.
Last updated: October 2025