BETTER SAFE THAN SORRY – The case for building a robust sanctions compliance programme

The increasing number of enforcement agencies and their increasing vehemence in enforcement makes the risk of not keeping up substantial.

More than half a century ago, the U.N. Security Council (UNSC) established the first sanctions regime on Southern Rhodesia, now known as Zimbabwe. Since 1966, the UNSC has enacted 26 sanctions regimes, 13 of which continue today. Such small numbers belie the complexity organisations face maintaining sanctions compliance.

Sanctions regimes were devised as political apparatuses to prevent escalation or settle conflicts, curtail nuclear proliferation, and counter terrorism and human rights violations. While the current consolidated U.N. sanctions list only covers 13 sanctions regimes, the document is 158 pages long, reflecting the extensive collection of individuals, entities or States subject to sanctions. U.N. sanctions regimes are subsequently adopted by supranational bodies like the European Union, as well as individual nations. In addition, countries may have their own sanctions lists related to specific regional threats or other national security considerations.