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Compendium: High Level Review of United Nations Sanctions
tion to cooperation with other international bodies on sanctions implementation—were also noted. There is currently no mechanism for expert group
recommendations or procedures of one committee to be applicable to other
sanctions regimes so as to ensure consistent approaches to implementation
across regimes.
Uneven resourcing of individual sanctions committees was also a subject of discussion. The Subsidiary Organs branch (Sanctions Branch of the
Secretariat) organises its support along committee lines (that is, allocating
staff to support individual committees). This can result in inconsistencies in
the administration of different sanctions regimes and in the way committees
conduct business that are not justified by the technical requirements of the
regimes themselves. It also prevents the Secretariat from acting as a point of
coordination on committee practices.
Such technical inconsistencies do not serve Member States’ needs for
clear guidance on implementing sanctions. The current system provides multiple sources of sometimes inconsistent advice and different treatment of the
same types of measures. Worse, the system begins to have its own political
dynamic. Differing committee procedures, for example regarding the length
of time decisions can be deferred, lead to perceptions that some sanctions are
more important than others.
The consultations revealed that the two dimensions of sanctions
administration, the political (Member State engagement, decision making)
and the technical (dissemination of sanctions measures and guidance on
implementation), demand different approaches. The “political dimension” of
each sanctions regime requires a dedicated sanctions committee to manage
the relationships with interested States and organisations, to monitor implementation, and consider responses to noncompliance, as well as to make
decisions that are calibrated to achieving the goals set by the Council for that
regime. Examples of such decisions are exemptions from sanctions measures
or the application of sanctions measures to individuals or entities.
The “technical dimension,” meaning requirements for national implementation and the way in which these are communicated to Member States
and other relevant actors, is not well supported by the current structure of
regime committees and their supporting secretariat. At the national implementation level, the sixteen complex political situations to which sanctions
apply are distilled down to three or four regulations, each of which gives
effect to one of the broadly uniform sanctions types the Council applies (e.g.,
travel bans, asset freezes, and arms embargoes). The authorities administering
these regulations are concerned more with the consistent administration of