Thank you very much.
Chair and distinguished members of the committee, thank you for the opportunity to testify today.
I've been working on multilateral and autonomous sanctions for 20 years or so. During this time I've explored questions of the impacts, effectiveness and coordination of sanctions regimes, such as those targeting Russia, Syria, Afghanistan, Iran, North Korea and so on.
I've also researched sanctions in relation to areas such as chemical weapons abuses, nuclear non-proliferation, cybersecurity, modern slavery and human trafficking, and humanitarian considerations. I also coordinate several multi-stakeholder initiatives on sanctions on behalf of the European Union, the Swiss Federal Department of Foreign Affairs and the United Nations. In recent years, I've also provided testimony on sanctions to the U.S. Congress, both U.K. Houses of Parliament, the Canadian Senate and the European Parliament.
In 2020, I provided research and strategic policy advice to Global Affairs Canada's new sanctions unit, including a suggested checklist for sanctions design and a blueprint for areas where Canada could play a positive leadership role in global sanctions fora, drawing on its unique position in the world. I'll draw on this work today, as well as the testimony I provided to the Canadian Senate in December 2022.
I'd like to share reflections today on just two key areas that I feel most qualified to talk about and that relate to recommendations this committee made in April 2017 as part of Canada's parliamentary review on Canadian sanctions, which led to Global Affairs Canada being afforded stronger capabilities and more flexibility in the area of autonomous sanctions.
The first area is the recommendation to “properly resource and reform the structures responsible for [Canada's] sanctions regimes”.
An earlier criticism was that the Canadian government didn't have adequate resources to implement and enforce an effective sanctions regime or to allow for independent oversight of Canada's sanctions procedures. Important steps appear to have happened in the right direction in recent years through the establishment of the sanctions policy and operations coordination division, with stepped-up resourcing and legislative reforms. From my experience, this is staffed by extremely dedicated, expert and hard-working officials, who have adapted well to the fast-changing global sanctions landscape.
In response to earlier critiques over difficulties in navigating sanctions lists, Global Affairs Canada now has consolidated autonomous and UN sanctions lists on its website, and other sites also provide useful information on sanctions resources, such as that contained on the Parliament of Canada site. As I understand it, regular reviews are conducted, and Canada has also contributed to a number of detailed studies and tools that help aid sanctions design, both within Canada and globally.
Another notable change has been the rise in Canada's prominence in autonomous sanctions practice, in close coordination with the EU, the U.K. and the U.S. in particular, alongside others. I see this as something of a positive step that responds to recommendations that closer collaboration was warranted. The formalization and streamlining of these types of collaboration, I would say, is a merit of Canada's involvement.
In light of this close work with international partners, I'd say that Canada's sanctions use is increasingly “plurilateral”, to borrow the term from the World Trade Organization, and really not particularly unilateral—as per some critiques of autonomous sanctions—with between 30 and 40 countries working together. Given the impasse we see today on sanctions at the UN Security Council, this allows Canada to join allies in addressing breaches of international law and to play something of a leadership role in international foreign and security policy. This also serves, of course, as a force multiplier by working together.
We also see formalization and other types of collaboration, such as through the Russian elites, proxies and oligarchs task force, which is a multilateral effort that has used information sharing and coordination to identify and exert pressure on sanctioned Russian individuals and entities. Canada is, of course, a member, alongside a number of other different countries and the European Commission.
An expansion in terms of staffing, training, capacity and resourcing appears to be warranted, in my view at least, not only in Canada but also elsewhere, considering the very steep rise in prominence of sanctions we're seeing across the world today, and particularly following Russia's full-scale invasion of Ukraine in 2022.
If we take a couple of examples from elsewhere, the U.K. sanctions unit has grown dramatically in recent times and is now sitting at around 160 individuals. The Netherlands has just seen the creation of and growth in its own sanctions unit. This has been happening elsewhere as well. This gives a kind of context in terms of the need for proper resourcing across the board of different areas.
I will make a very quick point to conclude in terms of the recommendation for Global Affairs Canada to provide comprehensive, publicly available written guidance to the public and private sectors regarding the interpretation of sanctions regulations in order to maximize compliance.
Canada, of course, lacks an investigative or enforcement body like OFAC in the U.S. Treasury. Alongside this, we know that Russia and other actors are using sophisticated evasion and circumvention techniques in coordination with other sanctions targets, particularly DPRK, Iran and so on, so enforcement has now become the name of the game. I think we can learn some lessons from what other countries are doing.
We have seen the U.S. Treasury working together with the U.K. Treasury to develop common approaches in terms of enforcement and investigative powers. We also see the EU and U.S.—