If I have understood the question correctly, yes, it's extremely onerous for the private sector to comply with sanctions. There is an incredible industry of compliance, and the main enforcement of sanctions, certainly in the EU, comes from compliance rather than public enforcement.
Is there clear guidance? No. In my view the EU has been very bad, far worse than the OFAC in the United States, at publishing guidance on the meaning of its sanctions measures and how they should be applied. Of course, you could say that's fine because it's intentional. It leads to over-compliance by institutions trying to do the right thing, but I think a lot of people in business—entirely innocent business, if you like, which is not supposed to be subject to sanctions—find themselves turning in somersaults trying to work out how they can lawfully conduct their business. That is a huge externality, if you like, which has just become part of the system.
I think it's fair to say that is not part of the targeted sanctions problem, although to some extent it is. How can you do business without making funds available to a targeted person? I think the problems you've identified are far more with the less targeted parts of sanctions regimes.