Foreign Affairs committee  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 t

Foreign Affairs committee  Thank you for asking us. If there are particular topics of interest to the committee, I'd be very happy to provide notes in writing, and I will think about whether there is useful material to send now. But please don't hesitate to ask for particular items of information.

Foreign Affairs committee  I think the difficulty with evidence beforehand is that most, if not all, imposing authorities will say that, because of the risk of asset dissipation, they can't let someone know that they're going to have sanctions imposed on them before they're going to be imposed. The whole p

Foreign Affairs committee  In the case of the European Union, you write to the European Council and you make observations explaining why you think you should not be on the list. As I said in my opening remarks, the response, in my experience, is very frustrating, because it will be very slow and it will us

Foreign Affairs committee  To my knowledge we don't. The UN not only has a panel of experts but has, I understand, a separate panel of experts for each different sanctions regime, and that is staffed with people who know very clearly what's actually happening on the ground in that country, who in fact is o

Foreign Affairs committee  From my perspective [Technical difficulty—Editor] I don't have any such grid. I'm a mere litigator, I'm afraid. I'm very responsive to the individual questions of clients, but I don't study or pretend to study sanctions imposed by different entities overall. I follow it. I have a

Foreign Affairs committee  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 enforcemen

Foreign Affairs committee  I think the answer from the private sector would be, loudly and clearly, yes, please, they would love more guidance and they would love more clarity. I think the answer from the EU might be that it's difficult when you have 28 member states to pass these measures, first of all,

Foreign Affairs committee  Canada, like the United Kingdom and the United States and other countries, has agencies that are very used to gathering evidence in a domestic context, both legal enforcement and criminal law agencies, which have very good investigatory powers precisely to gather evidence against

Foreign Affairs committee  As you probably know, the European Union has not imposed a Magnitsky list—

Foreign Affairs committee  —but that's very controversial, and members of the European Parliament have repeatedly called on the EU to do so. Some countries feel very strongly that there should be a list. It has not been possible to reach an agreement on it. I think that serious human rights violations ar

Foreign Affairs committee  Thank you very much, and thank you very much for inviting me. It's a great honour to appear before you. I should say that I gave evidence to our own Parliament, to the House of Lords EU Justice Sub-Committee about two weeks ago, because they have been inquiring into various aspe