Source · Select Committees · Foreign Affairs Committee
Recommendation 12
12
Accepted
Paragraph: 30
The primary reason for early ineffective action on sanctions was inadequate preparation and foresight by...
Recommendation
The primary reason for early ineffective action on sanctions was inadequate preparation and foresight by the leadership of the FCDO and consequent understaffing within the sanctions unit. The skillset of staff within the sanctions unit and the coordination between departments to understand the commercial environment are critical. We welcome the Government’s expansion of the sanctions unit. But policy effectiveness requires practical backing, sufficient resources and 26 The cost of complacency: illicit finance and the war in kraine the right capabilities, including the capacity to gather necessary intelligence to support designations. The Government should provide the sanctions unit with the necessary additional resources for the duration of the crisis. We recommend that the Government develops a professional sanctions cadre, to develop sanctions design and targeting as a recognised professional specialism. The UK is a global financial centre with access to this information; we should make better use of it.
Government Response Summary
The FCDO has established a permanent Sanctions Directorate and a cadre of sanctions experts to build enduring expertise. This includes training for staff across the FCDO and wider government.
Paragraph Reference:
30
Government Response
Accepted
HM Government
Accepted
The FCDO and partners across government were in close coordination throughout the months leading up to the Russian invasion, which proved pivotal to the swift designation of individuals and introduction of new measures within days. Two weeks before the invasion, on 10 February, the Foreign Secretary introduced secondary legislation (The Russia (Sanctions) (EU Exit) (Amendment) Regulations 2022) which broadened the definition of ‘involved person’ in the designation criteria under the Russia Sanctions Regime. The legislation enabled the Foreign Secretary to sanction more individuals and entities at greater pace. Since then, the UK has launched the largest package of sanctions in its history. The designations and measures are inflicting devastating economic pain on Putin and Russia following the illegal and unprovoked invasion of Ukraine. We agree with the Committee that imposing new designations at pace is central to an effective sanctions response. It is, however, vital that we ensure these cases are properly prepared, and that sufficient evidence is gathered before we sanction these individuals. We agree with the Committee that the skillset of staff focused on sanctions has been central to our success in bringing these sanctions to bear. In December 2021, there were 48 substantive roles in the Sanctions Unit (now Sanctions Directorate). By the end of April 2022, there were around 150 people in the Directorate, consisting of an increased number of substantive roles and varying numbers of staff surged into the team on a temporary basis from other parts of the organisation. These figures also do not factor in those working across FCDO and its overseas network who cover sanctions as part of their wider roles. 10 The cost of complacency: illicit finance and the war in Ukraine: Government Response In recognition of the central role sanctions continue to play in the UK’s response to Russia’s illegal invasion, and of the role sanctions play as a key UK foreign policy tool, the FCDO has established a permanent Sanctions Directorate. The work of this Directorate will focus on the Government’s Russia Ukraine response and the 30+ UN and UK geographic and thematic sanctions regimes around the world tackling issues such as human rights, cyber, and terrorism. In line with the recommendation on a sanctions cadre, as part of the new Directorate, the FCDO has also established a cadre of sanctions experts to build the enduring expertise we need long term. This includes training for staff across the FCDO and wider government.