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Making Targeted Sanctions Effective - Small Arms Survey

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PART IV: TARGETING THE TARGET | 93<br />

• Poor implementation by Member States, particularly key states, actors<br />

and entities.<br />

• <strong>Targeted</strong> actors are likely to utilize a range of strategies before and<br />

after sanctions are implemented including:<br />

1. Use of intermediaries, front companies and organizations to<br />

evade sanctions;<br />

2. <strong>Making</strong> representations to third countries seeking assistance<br />

with sanctions evasion;<br />

3. Justifying their evasion of sanctions on human rights<br />

grounds, which may or may not be substantiated;<br />

4. Using propaganda and/or media campaigns to make arguments<br />

justifying their evasion of sanctions and objections to<br />

sanctions.<br />

• Member States may be reluctant to implement mandated sanctions<br />

if they are seen to be overly broad, or to conflict with country-specific<br />

legal rights of their citizens/residents, such as free speech (affects<br />

bans on representation), right to asylum (affects bans on residence),<br />

or economic and social rights (affects financial sanctions).<br />

• The value of inducements and positive measures is overlooked as<br />

means of promoting compliance in the target country and cooperation<br />

from third states.<br />

§ 270<br />

The issue of targeting is a matter that affects the sanctions regime<br />

throughout the entire operation. There are distinct stages or phases,<br />

however, and in the following these are used to organize the recommendations.<br />

<strong>Sanctions</strong> move from an initial phase of preparations,<br />

sometimes including feasibility studies or other preparatory work:<br />

the Planning Phase. The Member States then take on the responsi-<br />

■<br />

Planning<br />

➞<br />

➞<br />

▲<br />

Operations<br />

Figure 1.<br />

Phases in Targeting<br />

➞<br />

●<br />

Follow-up<br />

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