28 Compendium: High Level Review of United Nations Sanctions D. Individuals and entities named in expert group reports HLR consultations also considered the situation of an individual or entity named in an expert group report in connection with a sanctions violation or as a candidate for sanctions designation by the committee. Unlike an individual or entity actually included on a sanctions list, there was no recourse for those merely named in reports, despite the fact that serious reputational and financial consequences could result (for example, inclusion in commercially produced AML/CFT monitoring and screening databases). There were mixed views on whether expert groups should be bound to provide a “right of reply” to such individuals or entities. Providing such a right of reply should not be a precondition of naming the individuals and entities in the reports, given that many were difficult to contact (insurgent groups) or politically non-cooperative. The situation of individuals and entities that may be named is not as clear-cut as for a Member State named in a report. The real issue is the operational appropriateness of naming them in the report in the first place. Non-state actors generally are not bound directly by the Security Council’s resolutions, but rather by the national laws of Member States implementing those measures. If the individual or entity is suspected of acting in contravention of the sanctions, there is a risk that notifying them of this suspicion and the evidence for it may jeopardise national investigations or proceedings against them, by “tipping off” the suspects to the investigation. Individuals and entities can of course be placed under sanction by the Council or a committee if they meet the relevant designation criteria. Providing them with prior notice of the possibility of their inclusion on a sanctions list through reference in a report has the potential to defeat the purpose of targeted financial sanctions, by enabling the possible target to conceal their assets in advance of the listing. 18. The names of individuals and entities suspected of acting in contravention of sanctions measures, or proposed by expert groups for designation by a sanctions committee, should be conveyed to the committee in confidence, and should not be included in the published report. The committee and the expert group should liaise with the authorities of Member States with jurisdiction over the conduct concerned to share information in support of designation under sanctions or prosecution under national law.