Euro SIFMANet: Barcelona Report - The Role of Data in Sanctions Implementation

During the design of the sanctions packages imposed on Russia following its full-scale invasion of Ukraine in February 2022, the initial focus was on throwing the net as wide as possible. The aim was to impose restrictive measures on a broad range of financial and trade activities. However, following the early flurry of activity, attention has now shifted towards ensuring effective implementation and enforcement.

Over nearly two years, the RUSI-led European Sanctions and Illicit Finance Monitoring and Analysis Network (SIFMANet) has highlighted the main structural challenges faced by EU member state national authorities, and businesses with sanctions responsibilities. 1 It has also identified that all stakeholders – whether private sector actors seeking to improve their implementation or governments monitoring for circumvention and evasion – need better data. This would allow sanctions to be more effectively implemented, and circumvention and evasion more effectively tackled.

To gain insights on this issue, the Centre for Financial Crime and Security Studies (CFCS) at RUSI hosted a roundtable discussion in Barcelona in November 2023, with the support of Dow Jones Risk & Compliance. The event gathered sanctions experts from the public and private sectors across different European jurisdictions to explore, under the Chatham House rule, the role of data in strengthening the implementation and enforcement of sanctions. This engagement was part of SIFMANet’s activities supported by the National Endowment for Democracy, and along with a video filmed on the day, 2 this report presents the main findings from the discussion.