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Life cycle of a sanctions programme

Market Insight
6 September 2013

The continued increase of multilateral sanctions against Iran and speculation about action against Syria offer a useful contrast to the lifting of sanctions against Burma, such that now is an appropriate time to look at some of the trends and common features in EU sanctions programmes, with a particular focus on how those programmes have developed over time and what commercial organisations might expect if they are affected by them.

This article first appeared in WorldECR, the journal of export controls and sanctions, July/August 2013 issue and is reproduced with their kind permission.

The political basis for international trade sanctions is that they are intended to address particular circumstances and operate to achieve particular foreign policy objectives. As a result, the sanctions should be dynamic, rather than static, pieces of legislation and they should be focused on specific, clearly identified policy objectives. They should be targeted to address the needs of the specific political situation, and more onerous sanctions should only be imposed if these are needed to ensure that the relevant public policy objectives are achieved. The restrictions and prohibitions should then be progressively reduced when events on the ground show that the sanctions programme is achieving its stated objectives.


This article will look in particular at the EU sanctions against Ivory Coast, Libya, Iran and Syria as a guide to the ways in which sanctions have historically been increased in response to political events. We will also look at the sanctions against Ivory Coast and Libya as a demonstration of how the sanctions have historically been reduced in response to political events.

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EU Sanctions: Common Features

We will focus on “trade” sanctions i.e. those which prohibit or otherwise restrict some or all trade between the sanctioned regime and commercial organisations elsewhere.

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EU Sanctions against Ivory Coast

In the case of Ivory Coast, a package of measures was adopted in January 2011 by the EU, following the refusal by the ex-President, Mr Laurent Gbagbo, to accept the result of a presidential election.

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EU Sanctions against Libya

A similar model was followed in the case of the EU sanctions against Libya. Sanctions were first imposed in March 2011 (by Regulation 204/2011) and comprised both an asset freeze, and also restrictions on the supply of military and quasi-military equipment to Libya. The initial asset freeze applied to 26 individuals.

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In the case of both Ivory Coast and Libya, the initial asset freeze was targeted at those individuals most closely connected with the regime, and was expanded relatively rapidly to encompass a host of individuals and entities with links to that regime.

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EU Sanctions against Syria

EU sanctions against Syria were first imposed in May 2011. As with the measures against Ivory Coast and Libya, the sanctions initially comprised an asset freeze, in this case directed against 13 individuals, all closely connected to the Assad regime, supported by a prohibition on the supply of military and quasi-military equipment to Syria. The asset freeze was expanded in May, June and August, with the result that by 24 August 2011 (less than six months after sanctions were first imposed), a total of 50 individuals and 9 entities were subject to the EU asset freeze.

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EU Sanctions against Iran

Likewise in the case of Iran, EU sanctions imposed in 2007 were limited to an asset freeze against 10 entities and 12 individuals, plus an embargo on a limited number of items for Iran’s nuclear programmes, in order to implement the measures in UN Resolution 1737(2006). Throughout 2007, 2008, 2009 and 2010 more individuals and entities were added to the sanctions list, with the result that by October 2010 over 70 individuals and over 120 entities were subject to the asset freeze.

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While usually described as “smart” or “targeted” sanctions, the current package of measures against Iran is so wide-ranging as to amount to a virtual embargo on trade with Iran. Recent political rhetoric in the EU and the US has tended to focus on the “toughness”, “comprehensiveness” or “breadth” of the measures, rather than on their effectiveness, or the criteria to determine whether the restrictions are achieving their aims.

That makes it difficult to assess the overall effectiveness of sanctions as a tool of foreign policy. In addition, in circumstances where restrictions are not tied to particular objectives, it is difficult to see how it could be said that a particular objective has been achieved and that in turn makes it difficult to assess how and when particular restrictions will be relaxed or lifted if there is progress in persuading Iran to change its policies.


It will have been seen from the above discussion that sanctions programmes can change very rapidly in ways which can be difficult to predict. The changes can have huge implications on commercial organisations engaged in international commerce, but they are frequently introduced with little or no advance warning and commonly do not include grandfathering or wind-down provisions.

Commercial organisations such as traders, transport operators, insurers and banks find themselves at the sharp end, with a high compliance burden, and with changes to sanctions programmes presenting them with threats or opportunities as restrictions and prohibitions are introduced or withdrawn.

As a result, commercial organisations engaged in international commerce not only need to exercise vigilance and check the status of the counterparties and goods they deal with, but also need to keep themselves updated as to changes in the relevant legislation to avoid risks and seize opportunities. Having an ear to the ground for future developments can be invaluable.

For more information please contact Daniel Martin, Partner, on +44 (0)20 7264 8189, or

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