Foreign Affairs committee  Thank you, Mr. Chairman. We're happy to do whatever else we can to help.

Foreign Affairs committee  I would just add that there is a role, short of UN sanctions. I agree. I think it's very important to get as many member states committed to the sanctions as possible, but even without having a UN Security Council resolution, there are other ways for states to coordinate like-min

Foreign Affairs committee  I would just add that I think sanctions have been a boon for lawyers and for consultants. My own personal view, both when I was on Capitol Hill and when I was in the executive branch, is that people shouldn't have to pay to make sure they're complying with the law. There should b

Foreign Affairs committee  I don't know if I could characterize the opinion of policy experts. It is congressional legislation that the executive branch is implementing. What's the purpose of it? Is it going to coerce the individuals? I'm not sure that we've seen that it has been particularly effective in

Foreign Affairs committee  Increasingly when using UN sanctions, when we did the assessment in terms of impact and effectiveness, human rights are not commonly the primary purpose, but they are a purpose for numerous sanctions regimes that the UN implements. In fact, there has been an evolution in which we

Foreign Affairs committee  I would also commend to you this High Level Review of UN Sanctions that took place and was released last November. There is a review process which is starting this year. There were 150— I know it sounds daunting—recommendations of things that could be done at the UN international

Foreign Affairs committee  Not as a leader.

Foreign Affairs committee  Could I add two quick points to that? One clearly is, you're absolutely right, the effectiveness of the UN measures depends on how, for example, China is interpreting “luxury goods” and whether they interpret that and then enforce it. That's all the more reason that we need to wo

Foreign Affairs committee  That's a good question. I think the provision you're talking about is in the model legislation. This was, in particular, to protect banks. When you freeze assets and you're relying on the government's action, they get what's called a “safe harbour” from being sued. That has been

Foreign Affairs committee  A country that has the sophistication and the legal basis regulatory system that it does and the confusion that exists.... Think about another member state of the UN, say an African country; trying to understand what the sanctions are intended to do and how to implement them can

Foreign Affairs committee  Yes. That goes back quite some time. It's good to know that people are still looking at the Interlaken manual. Beyond Interlaken is the Bonn-Berlin...focusing on arms embargoes, aviation sanctions, and individual bans on travel; and then the Stockholm process, which I would comm

Foreign Affairs committee  It varies in the different kinds of effects. I would be willing to say that U.S. sanctions and enforcement actions are quite significant. Probably the U.S. has more enforcement actions than any other country. It's the billion-dollar penalties that a number of banks have been subj

Foreign Affairs committee  On the whole question of compliance, it is undoubtedly true. Take, for example, the Libyan sanctions. When the UN sanctions on Libya were first applied, a number of us who'd been working in the area—because it was the first time that we had imposed sanctions in the context of R2P

Foreign Affairs committee  Well, let me just supplement. I think it depends on what you want to achieve by these sanctions. I was a regulator. I administered dual-use export controls for the United States and the Clinton administration. I was looking for what the violations were and what people were doi

Foreign Affairs committee  Perhaps I could start. The sanctions now, by and large, are targeted. Whether they are UN sanctions or national measures, we have tried to target individuals and their behaviour and tried to focus on the kind of objectionable behaviour we want to change. Most of them are targeted