Committee decision-making 31 the potential to erode the credibility of UN sanctions and negatively impact implementation by Member States. It was considered important, therefore, by many HLR participants, to continue efforts to ensure the fairness and transparency of sanctions procedures and to address human rights and due process issues at the UN level. Notwithstanding these reforms by the Security Council, HLR consultations revealed strong views by some that additional steps are needed to improve the procedural rights of individuals and entities subject to sanctions. Many called for the Office of the Ombudsperson to be given jurisdiction to review all petitions arising from the listing decisions of the sanctions committees. Some called for the Ombudsperson to review listing decisions also before they were made. Proposals by the informal group of like-minded states on targeted sanctions advocating that the Ombudsperson process should be gradually extended to other appropriate sanctions regimes were considered. The Review also heard countervailing political and procedural views to these proposals. Consultations also noted the need for improved procedures on national/regional levels, and the European Union is considering EU institutional and procedural improvements, so as to effectively defend challenges to Security Council listings. The Review also considered whether empowering the Focal Point with additional authorities—to gather information as currently done by the Ombudsperson (that is, to request information from a range of relevant States and expert group, to seek the views of the relevant committee upon receipt of the petition, and to facilitate the passing of questions from consulted States, the expert group or the committee to the petitioner) but without the Ombudsperson’s authority to question States, analyse the information requested and make a recommendation, could provide additional due process. Additional Focal Point-related proposals include requiring the committee to take a formal decision in relation to the petition; fixing a timeframe for decisions to be made; encouraging the provision of reasons to the petitioner for the outcome; and empowering the Focal Point to receive and transmit requests for humanitarian exemptions, as well as communications from individuals/entities in all regimes which raise issues of continued sanctions post-listing or mistaken identities.5 5 UNSC Resolution 2161 (2014) facilitates requests for exemptions under the financial and travel sanctions (other than in the context of a petition to the Ombudsperson), as well as to deal with cases of mistaken identity or continuing effects of sanctions post-delisting. Extending these measures to other sanction regimes would be a significant step forward for the fairness of the overall sanction process. Access to exemptions, and recourse in case of improper imposition of measures

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