EXECUTIVE SUMMARY
1. This report provides a high-level overview for the risk committee on how UK based International Banks are exposed to risks in relation to international sanctions. It focuses on the banks responsibilities and legal obligations to comply with both UK and international sanctions and outlines the consequences if obligations are not met.
2. This document outlines the legal framework in which UK banks must operate in relation to Sanctions.
3. A risk based approach is outlined for system and controls in place to avoid circumvention of international sanctions.
SANCTIONS BACKGROUND
i. What are sanctions: Sanctions are enforcement measures used by the international community to maintain or restore international peace and security without the use of armed force or international military action. ii. Types of Sanctions: Financial Sanctions can include Asset Freezing (Terrorist Asset Freezing Act 2010), (Govt Legislation, 2010) prohibition of certain investments, and prohibition to providing economic benefits. Trade Sanctions can be applied to stop arms embargoes and trade sanctions can be used to stop legitimate goods being used for military application. Goods such as fertilizer and medical equipment can have a dual purpose and used for warfare and nuclear weapons. Department for International Trade (Dept for International Trade, 2016) has a list of goods that are restricted due to their dual purpose. Enhanced Due Diligence (EDD) is required for anyone using
Currently, numerous sanctions target the Iranian economy. These sanctions are implemented and enforced by the United States of America, The European Union, and several other United Nation members to include; Japan, the Republic of Korea, Canada, Australia, Norway, Switzer. Fathollah-nejad, A. (2013). These measures are necessary to enforce international laws through means other than war.
While there are two ways to look at a problem, I believe that, for this issue, the negative side is more practical and efficient. The United States should not impose economic sanctions on Russia because of three reasons. The first, in my opinion, why is there a need for the US to impose sanctions in the first place? Why is it their responsibility to look after Ukraine? While I understand that it is somewhat expected of the US to
The sanctions center around the country’s ballistic missile program has also claimed human rights abuses and the Islamic Revolutionary Guard Corps(IRGC). The new law says the IRGC plays a large role in Iran’s international destabilization program, including terrorism and the ballistic missile program. The sanctions include the blocking property, exclusion from entering the US and pausing current transactions. However the Iranian government has accused the United States of Using the Sanctions to undermine the current nuclear deal. “President Trump has long criticized the agreement and vowed to pull the country out of it during his election campaign.”(CNN). Iranian Foreign Ministry spokesman Bahram Qasemi warned that “hostile” measures taken by the US would impact international relations and affairs.
As economic hegemony and political and military superpower following WWII, the United States attempted to impose its will on many countries through the use of economic sanctions. There are many motivation prompting the use of sanction. First, it can be a proportional response to a challenge where the interests at stake are judged to be less than vital. Second, sanctions are a form of expression, to communicate official displeasure with a certain behavior or action . American reluctance to use military force is another motivation, especially in those instances where U.S. interests are not deemed sufficiently important to justify casualties and high financial costs. Third, the growth of congressional power helps explain the prevalence of economic
This paper focuses on economic sanctions target selection. It specifically examines which factors include United States’ decision to impose economic sanctions. Sanctions are penalties levied against another country, or individuals within a country. They are an instrument of national foreign policy designed to apply economic pressure against their target in order to changes the target state’s behaviors or polices. Sanctions represent a wide variety of policy tools available for use as part of a carrot and stick approach to international relations.
Economic Sanctions are a way of punishing errant countries which is more acceptable than bombing or invading them. It’s a way to sway the target government to change a policy. Some Sanctions include limiting export or import trade and preventing transfers of money involving citizens or the government of the target. Sanctions can be multilateral with many countries acting together or unilateral when one country takes action on its own. Between 1914 and 1990 there were 116 sanctions that were imposed on countries and ⅔ of these failed to achieve their stated goals. The cost of the country imposing the sanctions can be very large, particularly when the country is acting unilaterally. It is estimated that in 1995 imposing sanctions on other countries cost the American economy over 15 billion dollars in lost exports and 200 thousand in lost jobs in export industries. (Evidence on the Costs and Benefits of Economic Sanctions)
Targeted sanctions are by no means a perfect method for persuading a change of behavior. Sanctions bring with them collateral damage, including trade deficits and project partnerships with the target. Legal difficulties are another aspect which can slow the process of persuading a target to change their actions, thus adding to the collateral damage. Targeted sanctions should have very little collateral damage in terms of harm to civilians, and finding ways to deal with collateral damage should include some sort of humanitarian relief efforts for civilians in the targeted country. Under European Union law every action, including sanctions against a target, must follow legal protocol defined in the Treaties. These legal difficulties within the
Economic sanctions are implemented by one or more nations upon another nation in order to alter the nation's interests towards their own preferences. Economic sanctions have proven themselves to be successful countless times, and have incited successful negotiations that would have otherwise not existed. Sanctions do not aim to directly affect the citizens of a nation, but rather, as editor, Robert McMahon said in UN Sanctions: A Mixed Record, “sectors of a nation, such as arms, cash-earning commodities such as diamonds, or financial assets and travel”. Although an estimated 35% of sanctions have been successful, they have been very effective as a foreign policy tool and have somewhat prevented nations from violating human rights as well as acts of terrorism. Although economic sanctions have an estimated 35% success rate, they are still extremely useful and lead to negotiations between parties with different interests. This is because, sanctions are able to instill fear in other nations which in turn prevents the occurrence of any malicious
in 2010 announced unilateral sanctions against Iran freezing the assets of Revolutionary Guard members. Three rounds of sanctions that Iran routinely ignored followed by a promise by the Obama administration and that if their next round of sanctions don't work to embargo the refined oil to the not have enough refining capacity is suddenly cannot get any gas you could create a crisis of a rather large variety in that country Iranian response has been to threaten closing shipping traffic through the Strait of Hormuz, this would cause probably instant military as it would be incredibly damaging the world oil markets considering the world economy runs on oil this would have the effect of angering every nation even China and Russia like the Iranians the way the sanctions would work The legislation would impose sanctions on any company that sold or delivered gasoline to Iran, cutting it off from selling to the United States government and seeking to freeze its financing or shipping insurance. Another issue that may prevent us from actually doing this is that Iran currently suffering from a severe amount of internal chaos given President Mahmoud Ahmadinejad essentially stole his election would have been great widespread protests and riots in that country one problem with engaging sanctions like this is that it may allow the Iranian president to shift focus from his problem with legitimacy of governance to blaming the West for the country's problems and you'll
In this Essay I will explore the Proposals put forward by the UK government in the 2011 “Vickers Report” as well as exploring the proposals I will then give an in depth analysis in how effective the methods put forward are; in terms of how successful they are in ensuring financial stability within the current economic climate. Furthermore I will examine how these proposals are being enforced by UK law to achieve practical outcomes, as theoretical tools do not always work as imagined in real life scenarios.
Resolution 1737 (2006); the Security Council today imposed sanctions on Iran, blocking the import or export of sensitive nuclear material and equipment and freezing the financial assets of persons or entities supporting its proliferation sensitive nuclear activities or the development of nuclear-weapon delivery systems
One of them restricts the trading Venezuelan Bonds “sold by government in the American financial markets to raise money.” (Krauss, 2017). Another, prohibits the “imports of Venezuelan crude oil to American refineries.” (Krauss, 2017). Since Venezuela is an oil-depending economy, the sanctions deny the Maduro administration any source of financing; basically, isolating the country from any business opportunity. Most of these sanctions occurred due to questionable government practices, their lack of respect for human rights, and their obvious corruption in the political practices.
The international community started to react against Iran nuclear program (Thompson, November 20, 2013). A sanction against Iran was passed by the UN Security Council after Iran did not stop its nuclear program. Sanctions could be said to be both effective and
The deployment of economic sanctions on the international stage by states to influence the behavior of other states has become the norm in International Relations. Despite the increase in popularity of this practice over the course of the past century, the question of its efficiency is one that is still debated and remains unanswered. The idea that putting economic pressures on a country to illicit a certain behavior or change in behavior from that country works in theory, but in practice, it is more complicated and does not necessarily work the way that theory suggests it should. Some economists and policy analysts have taken the approach of deconstructing the subject in order to consider what variable may or may not affect the efficiency
In an attempt to critically evaluate the effective implementation of the Greek regulatory framework against money laundering into the internal regulation of the Greek banks, several obstacles have arisen in obtaining relevant information, given that restrictions on publication of information relating to money laundering issues have been imposed. As a matter of fact, it is considered appropriate that “National Bank of Greece” and “Piraeus Bank”, two major Greek banks, which undertake numerous high-volume transactions, to be subject to examination as to whether they have acted with sufficient diligence to ensure the adoption of required measures in their compliance policy against money laundering.