9th International Compliance Forum Discusses Sanction Implementation
“Sanctions Alone Cannot Bring About Change; They Are Part of a Broader Foreign Policy Framework”
In Nicosia, at the 9th International Compliance Forum, the intricate yet essential subject of international sanctions was discussed. These sanctions aim to deter and disrupt illicit activities and to shed light on the reputational consequences for those with criminal intentions.
British High Commissioner to Cyprus, Irfan Siddiq, detailed the UK's approach to sanctions in his address. For the UK, sanctions serve as a foreign policy instrument designed to modify the behaviour of its targets, but they are applied under UK domestic law. He outlined three primary reasons for the UK's imposition of sanctions:
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Deterrence: Change the targeted individual or entity's behavior.
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Disruption: Restrict access to resources, making it harder for them to continue their adverse actions.
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Reputational Impact: Even if assets remain unaffected, the mere act of imposing sanctions aims to tarnish the target's reputation.
Siddiq explained that sanctions can take various forms: financial (like asset freezing), trade-related (such as arms embargoes), or personal (including travel and immigration bans). He emphasized, “Sanctions alone cannot bring about change; they are part of a broader foreign policy framework.”
Highlighting their effectiveness, he referred to the sanctions levied against Russia post their Ukraine invasion. In collaboration with the EU and G7, the UK applied what Siddiq described as "the most severe package of sanctions ever imposed on a major economy." This has significantly impacted the Russian economy, with a massive decline in bilateral trade between the UK and Russia.
The High Commissioner also expressed concerns about entities in Cyprus facilitating sanctions evasion. The UK is diligently working to close any existing loopholes and has committed 50 million pounds towards a new economic deterrence initiative specifically to counteract this evasion.
Dr. Marcus Pleyer, from Germany’s Federal Ministry of Finance, emphasized the importance of company-wide adherence to compliance values. Companies should be driven by values, such as preventing wars or combating terrorism, to ensure the effective implementation of sanctions.
Giles Thomson, from the UK’s Treasury's Office of Financial Sanctions Implementation (OFSI), spoke about the challenges and implications of sanction implementation. He noted the importance of collaboration with various sectors, including finance, accounting, legal, and crypto, to ensure effective sanction enforcement.
In his welcoming address, Marios Skandalis, Chief Compliance Officer of the Bank of Cyprus, underscored the significance of embedding a compliant culture throughout an organization, suggesting that a flexible and evolving company culture results in better business outcomes.
During a panel discussion moderated by Skandalis, Jacqueline Brewer of the US Treasury Department remarked on the evolving nature of sanctions – transitioning from broad to more targeted, enhancing their effectiveness. Giles Thomson reiterated the complexity of recent Russian sanctions, and Constantinos Trikoupis of the Central Bank of Cyprus discussed the harmonization of sanctions for efficient implementation.
Trikoupis concluded by highlighting that while the sanctions have a cost, there doesn’t appear to be a significant impact on Cyprus' economy from these sanctions.