I know of no system that doesn't do it that way, because I think anyone would say of course there are some penalty-type decisions where the only fair process is to give someone a warning in advance that you're going to impose a penalty and have the process in advance. Certainly the European system, and I'd be surprised if it was not also the UN and U.S. and Canadian systems, is that the due process has to come afterwards with an opportunity to be delisted swiftly if that's the right result. Otherwise, if someone tells you tomorrow that you're going to have your assets frozen next week but it hasn't happened yet, if this is someone who really should be sanctioned, then why wouldn't you simply remove all your assets from that jurisdiction? I think it's very difficult to provide process in advance but I think the key is swift and efficient due process as soon as possible after the event.
On November 2nd, 2016. See this statement in context.