Page:Twelfth Report Defeating Putin the development, implementation and impact of economic sanctions on Russia.pdf/19

46. unit in FCDO. The question I have is: does that tripling of capacity have the expertise to deal with the challenge that is ahead? I think we need to make sure that whatever OFSI does to expand [ ... ] in order to meet the current challenge, we need to make sure that that expansion is not just people, but people with the necessary expertise.^[1]

47. He added that:

    Obviously, the UK is faced with an unprecedented workload, and as I think we can all agree, OFSI was not set up to deal with what it is facing at the moment. We have to be realistic and, if you like, fair to it. The question is: how do we, as quickly as possible, ramp up capacity and ramp up guidance and everything that is needed?^[2]

    On expertise, and as way of example, he noted in relation to previous sanctions regarding the annexation of Crimea, that he had been told that no one involved with sanctions enforcement at that time could speak Russian.^[3]

48. Dr Justine Walker, Head of Global Sanctions and Risk at the Association of Certified Anti-Money Laundering Specialists, provided the following comparison of the scale of the UK enforcement operation to other countries:

    [ ... ] It is very clear that there has been a long-standing conversation and question around UK enforcement action. In comparison with the US, we see a lot less enforcement action. We are obviously a smaller country. I would also say that if you are comparing numbers, as people are looking at numbers here, the Treasury—the [United States Office of Foreign Assets Control] OFAC side—has hundreds upon hundreds of staff, and it is only covering the OFAC element, not the wider Treasury aspect. We do not have the comparable resources, so it does really depend on who you are comparing us against.

    If you compare us against somewhere like the US, we do not meet that. If you compare us against many of our European partners, we look quite good, so it depends on what you are looking at. Yes, I would accept that there is maybe a reason to look at the enforcement numbers. Enforcement does focus compliance thinking.^[4]

    The US OFAC was reported to have had 204 staff in 2020, against authorisation for 259 full time equivalents.^[5]

49. The sanctions against Russia are without precedent given the size of its economy and its integration with the West. The implementation of sanctions requires compliance action by the private sector. We are therefore concerned that guidance for those who have to implement sanctions has, at least in the initial stages, appeared to have

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1. Qq86—87
2. Q9
3. Q91
4. Q90
5. US Government Accountability Office, Economic Sanctions: Treasury and State Have Received Increased Resources for Sanctions Implementation but Face Hiring Challenges, March 2020