Implementation
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C. Cross-regime assessments and lessons learned
As will be discussed in the following section, expert groups are mandated
by the Security Council to report on sanctions violations. A symptom of the
“siloed” approach the Council currently takes to sanctions is that little systematic assessment of these reports is conducted to compare patterns and trends in
sanctions violations. Such analysis, particularly if cross-referenced to similar
analysis done by other entities, such as the typological work of the FATF
(although specifically related to sanctions countering terrorism or proliferation financing, the lessons can be extrapolated to other financial sanctions),
the World Customs Organisation (WCO) on arms trafficking, or export control mechanisms, could be helpful in understanding the scope and impact
of the sanctions, contribute to improved sanctions enforcement, and help
raise awareness among states about UN sanctions obligations. This should
include experiences gained by the 1540 Committee in facilitating adoption
of national implementation plans, promoting national interagency efforts,
enhancing synergies of international and regional organizations, and building partnerships with key stakeholders including civil society and industry.
11. The Council should undertake a “lessons learned” exercise concerning the
implementation of sanctions, based on a comprehensive study and analysis of sanctions violations and evasions across regimes. Research by other
entities on matters useful in discerning patterns and trends and in preventing and detecting illicit movements of goods, people and funds
across borders, should be utilised.
12. As part of the study and on a regular basis, the Subsidiary Organs Branch
should convene topical discussions among functional contact groups with
sanctions stakeholders, including the private sector, to identify cross-regime
sanctions compliance challenges.