The past decade has seen a significant shift in global sanctions practice, away from the targeted or “smart” measures that characterised the 2000s. Teemed with a rise in counter terrorism (CT) and anti-money laundering (AML) regulations, this has resulted in financial sector over-compliance, or “de-risking”, and a withdrawal of humanitarian organisations from some of the world’s most complex and pressing humanitarian emergencies (the “chilling effect”). The phenomenon also presents complex and costly barriers to private sector companies playing a vital role in the trade of essential goods to these so-called “high-risk" jurisdictions, including medical and food companies, alongside insurance and shipping firms.
Funded by the Swiss Network of International Studies (SNIS) and running from 01 October 2020 for two years, ours will be first empirical study comparing the risk mitigation strategies used by non-state actors involved in the delivery of food and medicine to heavily sanctioned jurisdictions, such as Iran, North Korea, Venezuela and Syria.
Our multidisciplinary project uses a mixed-methods approach based on qualitative interviews with executives in food and medicine companies, international organisations (IOs) and non-governmental organisations (NGOs) based in Europe, North America and Asia, to test the assumption that export strategies may differ depending on the regulatory regime in which export companies operate, in spite of the relative “globalisation” of sanctions law. This large-scale interview campaign will be complemented with the circulation of an anonymised quantitative survey to industry and humanitarian practitioners.
In addition to contributing to regime complexity theory and filling other important gaps in the academic literature, this study will provide urgently needed policy contributions by identifying ways of better securing the continuation of food and medicine delivery in contexts of humanitarian crises. The elaboration of policy recommendations will be steered through multi-stakeholder focus groups, involving a network of leading humanitarian non-state actors, social scientists and international law specialists. Through research articles, a policy report and multi-media dissemination, these policy recommendations will have particular relevance in light of the COVID-19 pandemic and subsequent global recovery, in due to the unique difficulties heavily sanctioned and other “unbanked” countries face in tackling the virus.
Timeline: October 2020 - Feb 2023
Media interview and appearances
Article reprinted from the December 2020 issue of WorldECR, the journal of export controls and sanctions.