Fatih Şahin Фатіх Шахін Ukraine, business and international experience — since 2004
Foreign relations

What listing an individual actually does

Thousands of individuals have been listed. The effect is not what most people assume, and understanding it correctly matters for judging the regime.

Boundary marker of Ukraine
Photo: Andrew J.Kurbiko · CC0

Individual designations attract more coverage than any other sanctions instrument and are the most frequently misunderstood.

What a listing does

Assets within the jurisdiction are frozen — not confiscated, frozen: they remain the person's property but cannot be moved or used. Entry is prohibited. And, most consequentially, no regulated entity may provide services: no bank account, no lawyer, no accountant, no insurance, no property transaction.

That last element is the substantive one. A person cut off from professional services in a jurisdiction cannot operate there in any practical sense.

What it does not do

It does not change the behaviour of the person listed, usually. Anyone expecting listings to produce policy change through personal pressure will be disappointed, and that expectation has caused a great deal of unnecessary disillusionment with the instrument.

What it is actually for

Removing specific people from the international financial and legal system, so they cannot arrange transactions, move funds or hold assets through it. It is an operational measure against capability, not a persuasive one against intention.

The evidentiary discipline

Listings are challenged and some are annulled. Each annulment is reported as a failure and is better understood as the system working: a regime whose listings survive review is credible, and credibility is what makes the remaining ones stick.

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