A/HRC/45/7 violations, cases affecting a particular group or community, and the content of draft or existing legislation, policy or practice considered not to be fully compatible with international human rights standards. B. Cooperation with civil society 90. The Special Rapporteur believes that cooperation with civil society should not be limited to complaint procedures. Cooperation with relevant non-governmental organizations is a valuable means of obtaining up-to-date information about emerging and evolving human rights issues arising from the imposition of sanctions. Cooperation with large non-governmental organizations that operate internationally, address the range of human rights and also carry out research (Amnesty International, Human Rights Watch etc.) can be particularly useful, while cooperation on specific human rights issues affected by coercive measures can be developed with organizations that focus on those issues. 91. The Special Rapporteur notes the importance of the work done by academic institutions in terms of monitoring, researching and developing the legal understanding of the problem of sanctions and unilateral coercive measures and the effects of sanctions on the enjoyment of human rights. This includes not only academic work but also sanctions registries. Research on sanctions by scholars at Kiel University and Konstanz University of Applied Sciences in Germany and Drexel University in the United States, 64 for example, has led to the creation of databases that vary by types of sanction and time periods studied. Other databases, such as the targeted sanctions consortium database of the Graduate Institute of Geneva, are projects of the institutions themselves. 65 The Special Rapporteur welcomes cooperation with scholarly institutions, research groups and individual experts as part of civil society and believes that academics can play an important role in monitoring the impact on human rights of unilateral sanctions, identifying and interpreting the international laws applicable to their use and establishing the sanctions reference tool referred to below. C. Sanctions reference tool 92. The current situation is exacerbated by the complexity of the subject, the multitude of targets and types of sanctions and the complexity, opaqueness and confusing character of existing legislation. The absence of a comprehensive registry of sanctions adds to the challenge. Both international organizations and States maintain registries of sanctions imposed by them (see, e.g., the European Union sanctions map, the United States sanctions list and the United Kingdom sanctions guidance), which are often not easy to navigate. 66 Some databases have been established and maintained by scholars (see, e.g., the targeted sanctions initiative of the Graduate Institute of Geneva) but none of these is official. As a result, both international and national companies quite often have to pay risk assessment companies (see, e.g., LexisNexis Risk Solutions, the Payoneer Blog and the Association of Certified Sanctions Specialists). This approach prevents individuals and companies of the targeting, targeted and third States from being involved in the interaction. In particular, it has been reported that foreign companies refuse to deal with Syrian banks even if they are not on a list of sanctioned entities. 93. The absence of a comprehensive sanctions registry is in part due to the lack of an international legal obligation for States to be transparent about their sanctions or, by extension, about enforcement processes and penalties. One result is that it is unclear at times whether a Government’s announcement or threat of sanctions reflects actual legislation or regulations or is political rhetoric, in which case the latter may have the effect 64 65 66 16 Gabriel Felbermayr and others, “The Global Sanctions Data Base”, 14 October 2019. See https://graduateinstitute.ch/research-centres/global-governance-centre/targeted-sanctionsinitiative. See www.sanctionsmap.eu/#/main; https://sanctionssearch.ofac.treas.gov/; www.gov.uk/guidance/uksanctions.

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