Thank you very much for the question.
Again, I'm here in Washington, so perhaps I will give how we do it here in the United States. My answer is also based on having served in the U.S. Department of State for eight years during the Bush administration.
There are two departments that take the lead on sanctions. On the financial side, when it comes to assets, it is, as you said, sir, the treasury department's office of foreign assets control, OFAC. In my experience in government, and even out of government, I find OFAC to be one of the most effective agencies or offices within the treasury department. There are also sanctions that could involve visas, and visas are handled under the State Department, so there is the breakdown of responsibility, depending on the kinds of sanctions are imposed.
Most of the conversation, not only here today, but in general, is about financial sanctions, which our treasury department would take a lead on. With regard to denying people, say, Russian officials on the Magnitsky list—it's a privilege not a right to come to the United States, either themselves or their families—denying people I think is an effective tool. It's targeted. It's against individuals. It's not sweeping.
That involves the State Department. Visas are discretionary by nature, which means they cannot be challenged in a court of law. Financial sanctions could be challenged in a court of law. Therefore, they are subject to a higher evidentiary threshold. The treasury department has to make sure it could prevail should someone challenge those sanctions.