Whole of Government Approach
A Whole of Government Approach is the most effective method for a government to implement sanctions. Preferably, the Ministry of Foreign Affairs (MFA) would accept the responsibility to coordinate all implementation efforts as the principal conduit to the Security Council and its sanctions committees.
This approach requires a national policy, supporting laws and regulations, and the allocation of sufficient resources to fully enable the national implementation system. At a minimum the policy should address and issue regulations regarding:
- mandate for a national coordinator with responsibility and expertise for all issues pertaining to the national implementation of sanctions, including reporting obligations to the UN sanctions committees;
- mandate for an inter-ministerial mechanism, headed by the national coordinator and comprising technical experts from ministries and government agencies, to convene on a regular basis to collect and exchange information on the measures being taken and to identify loopholes in the implementation system;
- the question of which, if any, violations of UN sanctions can result in criminal prosecution and penalties;
- promulgation of national laws and regulations with extraterritorial reach regarding citizens or entities organized under national laws who violate UN sanctions;
- national regulations and licensing mechanisms for the export and transfer of catch-all controls for goods, components or technologies that are not specifically prohibited under conventional or unconventional UN embargoes;
- mechanisms through which relevant government agencies will conduct industry outreach and public awareness programs, as well as sanctions skills and training programs for front-line officials of the government, in particular law enforcement and customs and immigration officials.
The following illustration demonstrates how the Ministry of Foreign Affairs will act as the coordinating body for government organizations in charge of border control, defense and internal security and policing, regulators for the financial and transportation industries, trade and commerce including export licensing, or national security, and others, to enforce an effective government-wide response to all UN sanctions measures.