A/HRC/45/7 the more important, especially due to overcompliance by private actors and the increasing use of cybertechnologies. 44. The complexity, comprehensiveness and extraterritoriality of legislation have resulted in the establishment of workarounds. One such workaround welcomed by the Special Rapporteur is the Instrument in Support of Trade Exchanges (INSTEX), which was created in 2019 by France, Germany and the United Kingdom to foster trade between Europe and the Islamic Republic of Iran by circumventing United States sanctions against that country. The initial transactions have involved humanitarian goods used by the Islamic Republic of Iran to fight COVID-19.47 45. The Special Rapporteur also notes that there has been an equally significant expansion in the means and mechanisms of applying unilateral sanctions. In particular, the freezing of assets of State and private banks is being actively used to put pressure on States (the Syrian Arabic Republic, Venezuela (Bolivarian Republic of) etc.), thereby preventing them from procuring their citizens’ basic needs, including food and medicines, despite COVID-19. For example, the Bank of England refused to unfreeze any part of the US$ 1 billion in gold held from the Central Bank of the Bolivarian Republic of Venezuela during the pandemic (assets initially frozen to demonstrate non-recognition of Nicolás Maduro as President of the country), 48 not even, as reported by the United Nations Development Programme (UNDP), for procuring medicines and other humanitarian goods. 46. Political influence in international institutions has started to be used as a part of sanctions’ tools. In April 2020, the United States opposed the efforts of the Islamic Republic of Iran and the Bolivarian Republic of Venezuela to obtain a loan of US$5 billion from the International Monetary Fund for use in fighting COVID-19,49 despite repeated calls by the United Nations50 and the European Union51 to “leave no one behind” and to demonstrate solidarity and cooperation in the face of global evil. A similar situation has reportedly happened in respect of requests by Cuba and the Sudan for emergency loans from the World Bank. 47. The Special Rapporteur emphasizes the impact of the development of cybertechnologies on unilateral sanctions. The Security Council, in its resolutions 2419 (2018), 2462 (2019) and 2490 (2019), has recognized that the use by individuals and nonState entities of new information and communication technologies may constitute a threat to international peace and security. As a result, cyberattacks or other offensive uses of information and communication technologies can be considered grounds for introducing sanctions. United Nations organs have repeatedly called upon States to prevent the use of the Internet to advocate, commit, incite, recruit for, fund or plan terrorist acts (General Assembly resolution 73/174 etc.). Consequently, United States Executive Order 13694, as amended by later documents, introduced and expanded the list of “cyber-enabled activities subject to sanctions” 52 such as blocking property and interests in property in a broad number of cases, to include attacks on critical infrastructure, interference in the election process, disruption of networking or computer operations, misappropriation of financial funds and personal information etc. 47 48 49 50 51 52 “EU sells medical goods via INSTEX“ Financial Tribune, 3 April 2020. See Exclusive: Venezuela asks Bank of England to sell its gold to U.N. for coronavirus relief – sources 29.04.2020. Abubakr Al-Shamahi, “Can the IMF overcome US roadblocks to give aid to Iran?“, Al Jazeera, 17 April 2020; Ian Talley and Benoit Faucon, “U.S. to block Iran’s request to IMF for $5 billion loan to fight coronavirus”, Wall Street Journal, 7 April 2020. See also letter dated 29 May 2020 from the Bolivarian Republic of Venezuela addressed to the Special Rapporteur. General Assembly resolution 74/270 on global solidarity to fight COVID-19; OHCHR, “Bachelet calls for easing of sanctions to enable medical systems to fight COVID-19 and limit global contagion“, 24 March 2020; www.un.org/en/un-coronavirus-communications-team/we-are-alltogether-human-rights-and-covid-19-response-and. “EU will support Iran to receive loan from IMF: Borrell“, Islamic Republic News Agency, 23 March 2020; “EU foreign policy chief regrets US blocking IMF loan to Iran“, Radio Farda, 23 April 2020. United States, Cyber-Related Sanctions Program. 9