The recent spate of sanctions imposed by the west on individuals and organisations in China, Russia and elsewhere illustrates the continued importance of sanctions as a tool of foreign and national security policy. It also highlights the immense compliance difficulties they pose for banks.
A case in point is the coordinated action by the EU, UK, US and Canada in March to impose sanctions on officials in China for human rights abuses against Uyghurs. In the EU, they were implemented under the bloc’s new Global Human Rights Sanctions Regime (GHRSR) established last December. The regime also targets, among others, individuals in Russia for “arbitrary arrests and detentions … and systematic repression of freedom of peaceful assembly” and in Libya for “extrajudicial killings and enforced disappearances”.
