Implementation 17 B. Communicating implementation requirements Implementing sanctions is not straightforward. Sanctions measures can be complex and challenging to translate into national regulatory systems. Sanctions implementation also requires the existence of institutional capacity and resources within States to monitor borders, goods, and financial transactions. These difficulties multiply exponentially when seen from the perspective of the States whose implementation and enforcement of sanctions are most determinative of their effectiveness—the State to whose territory the sanctions apply and those States in its immediate region. The absence of, or inadequacy of national regulatory capacities, can be a contributing factor in the escalation of the crisis thus precipitating Council sanctions. As noted during HLR consultations, the first step toward “facilitating” implementation is to raise awareness of the sanctions regime’s existence and build greater understanding of the measures required. Sanctions resolutions adopted by the Council are often long and complex, and generally represent a cumulative process of addition and amendment. The absence of a clear articulation of the sanctions measures has an impact on implementation, not least given that in many States, the sanctions resolutions need to be translated into the national language for implementation purposes. Member States regularly called for sanctions implementation to be simplified and made consistent. Similarly, consultations revealed the impression that there is no timely or reliable source of assistance for Member States on sanctions implementation. Only five of the sixteen sanctions committees have produced publicly available implementation guidance on the measures they administer, and many of these relate to committee procedures rather than an explanation of the measures. Seeking advice directly from the committee takes too long; the monitoring and investigative role of the expert groups often leaves them with little scope to provide implementation guidance to States; and some Member States are reluctant to seek advice from the Secretariat owing to the sensitivity of the information. Member States contrasted this situation with the clear lines of communication and timely response in relation to the Council’s counter-terrorism obligations, through the Counter Terrorism Committee’s Executive Directorate. Participants also expressed concerns with the lack of consistency in sanctions implementation guidance. With each committee having a different dynamic and committee members being political rather than technical experts, technical implementation guidance risks inconsistencies across sanctions regimes. Differences of approach in basic administrative matters across committees—from the publication and dissemination of sanctions informa-

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