27/05/2019 - Private Actors and Sanctions: Lessons learned from the Netherlands

WHEN: 27 May 2019, 15:00–17:00

WHERE: MUP Prague-Strašnice building, Dubečská 900/10, Room no. 205

Free entry, no registration required.

Abstract: Non-governmental (NGOs) and intergovernmental organizations (IGOs) lament that working in countries under sanctions has become extremely problematic because financial institutions do not authorize any incoming or outgoing payments to or from sanctioned societies. The problem is that banks might decide to pull out from certain countries in order to minimize the risk of incurring into fines imposed by their own government or by the Office of Foreign Assets Control (OFAC) for sanctions violations. This phenomenon, which has been named over-compliance, highlights the centrality of private actors in the sanctions process, but a comprehensive study on how private actors affect sanctions policies is lacking. In this study, we explore the role of for-profit actors in the different phases of the sanctions cycle. The aim is to shed light on the process of sanctions formation with the objective to analyze how private actors can influence the outcome of policy process for the provision of security as public good. This paper is an exploratory research with the Netherlands as a single case study. The analysis is the result of two focus groups with representatives from the government (the regulators), the private sectors (the regulated) and academia that took place in Rotterdam in June and December 2018. The research has been complemented by interviews and desk research.