Absolutely. Thank you very much for your question.
I think judicial involvement in the sanctions process is critical to the integrity and legitimacy of the enterprise. At the outset, I want to make sure that I'm clear about that.
I would say that there are two characteristics of a sanctions regime that are important, and I think this has troubled the EU in some regard. I won't say that the U.S. does it better, but I will say I think the U.S. does it reasonably well.
The first is clarity about the process. What exactly goes into a decision to impose sanctions in the first instance? What institutional actors are involved? What are the legal criteria? What are their burdens of proof? What are the evidentiary thresholds? I think it's important that there's clarity about these issues and that they are foreseeable, and that this in some measure helps protect the due process rights of designated individuals.
Second, I think it is important that the courts have some ability to review classified information, information that's provided in confidence by the executive branch, but again, in order to protect the due process rights of sanctions targets, it's important that the sanctions targets know enough about the underlying conduct for which they have been designated that they can mount an effective defence.
These are the two principles that I would articulate as being important, and at least in the U.S. context, I would say we do reasonably well. There's always room for improvement, but I think we do these reasonably well, and they are important to focus on moving forward.