House of Commons - International Development

Select Committee on International Development Second Report

IMPROVING SANCTIONS

60. A great deal of activity is currently under way to examine how sanctions might be made 'smarter' and more effective. Conferences addressing the issue have included two conferences at Interlaken , Switzerland — "the Interlaken process"— examining the concept of targeted financial sanctions, and a seminar sponsored by the UK Department for International Development, hosted by the Overseas Development Institute (ODI). More recently, the German Government has sponsored a conference seeking to examine the potential for targeted arms embargoes and travel restrictions. Papers from these and other conferences have been published and placed on a Website, sponsored by the Swiss Federal Office for Foreign Economic Affairs.[67] As mentioned above, the UK Government, for its part, has recently completed a review of sanctions policy which concluded that there was a need for better targeted "smarter sanctions."[68]

61. There are two strands to the concept of smarter sanctions: to improve their efficacy by targeting those in power (and those who support them) and to reduce their humanitarian impact on civilian populations through improvements to humanitarian exemptions. These two elements of smarter sanctions have a common goal: that sanctions should be as effective as possible whilst, at the same time, having a minimal humanitarian impact.

Targeting Sanctions

62. The idea behind targeted sanctions is that, rather than targeting all imports and exports of all goods and services to a given state under a sanctions regime, a limited range of goods and services are targeted. The UK government, in evidence, accepted that "quite a lot of the product of our review [of sanctions policy] is precisely the conclusion that we need to move away from blunderbuss, hit the whole population type sanctions towards targeted, hit the regime and its supporters type sanctions."[69] Such sanctions seek to target the elites of a given regime, rather than the population as a whole. The United Nations Association of Great Britain and Northern Ireland outlined a number of possible targets for sanctions:

imposing a ban on all foreign travel for the political, civil service or military members of the government unless prior authorisation is given by the Security Council;
freezing all known assets of the offending leadership and their families;
cancelling all overseas training and other opportunities for members of the offending government and their families;
imposing a total arms embargo;
imposing, where relevant, no-fly zones;
prohibiting all external investment in the country unless it is authorised by the Security Council;
in cases of flagrant human rights abuses — pending the establishing of the International Criminal Court — the establishment by the Security Council of a Special Criminal Tribunal to investigate a situation.[70]

63. Whilst recognising that, as the above list demonstrates, targeted sanctions can take a number of forms, evidence to the Committee has focussed primarily on two particular targets: private finance and arms imports.

FINANCIAL SANCTIONS

64. Witnesses have suggested that targeted financial sanctions might offer significant potential to exert pressure on the political elite of a target country, by freezing the assets and blocking financial transactions of entities and individuals linked to the targeted government.[71] However, the potential of financial sanctions remains untested. In the words of Claude Bruderlein, "at the present stage, the financial assets of the political elite of targeted countries have often been left unaffected by UN sanctions regimes.... These assets have been allowed to circulate and fructify almost unhindered on international markets while the civilian population of the targeted country has had to bear most of the economic burden of comprehensive embargoes on national economic activities."[72] Furthermore, the UN has rarely mandated financial sanctions against individual members of a transgressor state, a point made by the Swiss Government in its presentation to the Interlaken Seminar, "In the case of Iraq and Serbia-Montenegro personal accounts of the political elites, e.g. Presidents Hussein and Milosevic, remained untouched."[73] There has therefore been a flurry of activity in recent years to examine how financial sanctions might be introduced as part of a package of smarter sanctions.

65. The ODI Seminar on Smarter Sanctions put forward the following potential advantages of financial sanctions:

By hurting the regime more than the general population they are morally more acceptable;
They avoid the humanitarian costs of comprehensive trade embargoes;
They therefore make the UN less vulnerable to the accusation that its policies violate human rights and subvert its own humanitarian obligations;
They therefore make it more difficult for the target regime to rally domestic and foreign support against the sanctions; those hurt are those with international money which is a minority of the population;
They minimise the costs to the close trading partners of the target state;
They deny the target regime the black market that enables the elite to profit from sanctions;
They deny the target regime the opportunity to extend its control over the population by taking control of humanitarian aid; and
They have fewer long term social costs and do less damage to the institutions of the targeted country.[74]

66. One example of the use of financial sanctions has been the case of Angola. UN Security Council Resolution 1173 adopted on 12 June 1998 stated that "all States, except Angola, in which there are funds and financial resources, including any funds derived or generated from property of UNITA as an organisation or of senior officials of UNITA or adult members of their immediate families... shall require all persons and entities within their own territories holding such funds and financial resources to freeze them and ensure that they are not made available directly or indirectly to or for the benefit of UNITA as an organisation or of senior officials of UNITA or adult members of their immediate families."[75] The financial sanctions imposed on senior UNITA officials are discussed in greater detail below. More recently, following the failure of the Taliban Islamic leaders of Afghanistan to hand over Osama bin Laden to the United States to face terrorist charges, the UN Security Council has imposed targeted financial sanctions freezing the Taliban administration's overseas assets and banning aircraft belonging to Atiana, the Afghan airline, from landing.

67. Whilst the Government has repeatedly made the case for "smarter sanctions", their memorandum provides very little information on means by which these objectives could be put into practice. The Government limits itself to broad policy objectives such as "sanctions should be targeted to hit the regime rather than the people."[76] We have sought to elaborate the means by which financial sanctions are implemented in the UK.

68. In the UK, the Treasury is responsible for implementing and enforcing sanctions which restrict payments, movements and change of ownership of capital and exchange. However, in these matters, the Treasury has appointed the Bank of England to act as its agent. The Bank is responsible for informing the banking sector of any financial sanctions that are put in place and for their enforcement. The identification and seizure of assets relies on banks enforcing principles of "know your customer", a point made by Simon Goddard of the National Criminal Intelligence Service, "If someone in a bank knows that this account relates to Mr Milosevic and there is in the press a lot of detail about his criminal activities, his black market activities, then they should rightly assume that they are the proceeds of crime and they should be reporting that to the NCIS."[77]

69. The National Criminal Intelligence Service explained in oral evidence that they did not have a significant role in sanctions.[78] Similarly, the Treasury at the time of their oral evidence were unable to offer any examples of assets being successfully identified and seized. In a supplementary memorandum to the Committee on the implementation of the financial sanctions imposed against UNITA, they told the Committee, "the Bank of England managed to trace a number of accounts held in the same name as some of the people designated [in the UN Resolution]. The Bank of England required further information in order to determine whether these accounts were held by people on the target list, or whether they were held by innocent individuals with the same name... The Foreign and Commonwealth Office, through the Angola Sanctions Committee at the UN, have asked the Angolan government on a number of occasions to provide further information regarding those on the target list... The Angolan government has been unable to provide this information. Consequently the Bank of England have been unable to verify whether any of these accounts should be frozen. They remain unfrozen."[79] Since that time, however, the Committee has received a further memorandum from the Treasury stating that, as a result of information received by the Bank of England from the Sanctions Committee on Angola, financial institutions in the UK had been able identify and freeze the accounts of two people.

70. The National Criminal Intelligence Service noted that, whilst they had examined proposals for interdiction software, no procedures had, as yet, been put in place: "We know the Americans have a system which allows them to put key words into ... software. For example they could put in the word 'Iraq' or 'Iran' and anything which came through the system would be identified. We do not have that. In the past we have looked at what the Americans are doing and we do look at what Australia do, who also have a similar software package. At the moment our system is based purely on the know-your customer and the role of the compliance officers."[80]

71. The Government's review of sanctions policy, made available, in confidence, to the Committee, also contains very little information on the use of financial sanctions, other than to assess their impact on UK trade and investment. Crucially, the review contains no proposals for improving financial sanctions as a tool of "smarter sanctions." We recommend that, in its response to this Report, the Government provide the Committee with details of existing measures taken to implement financial sanctions and a strategy for the relevant government departments to improve the effectiveness of such implementation, including the potential for the use of interdiction software. We are not convinced that enough effort is being expended by the United Kingdom Government to introduce effective procedures to implement financial sanctions. The United Kingdom is a world financial centre and a permanent member of the UN Security Council. If the United Kingdom does not take financial sanctions seriously, this fatally weakens the prospects for effective international action.

The Interlaken Process

72. The Interlaken process has, to date, consisted of two seminars attended by government officials, academics, and representatives from the trade, legal and financial sectors seeking to "develop new options, more targeted and more effective, driven by finance, rather than trade, and aimed at specific individuals and entities of the targeted country."[81] The two seminars, according to the Chairman of the Second Seminar, "made substantial progress in the discussion of the technical aspects of financial sanctions and mechanisms that should be in place to operate a credible targeted financial sanctions regime."[82] With both the Interlaken seminars now completed, the prospects for financial sanctions appear mixed.

73. Whilst, in theory, financial sanctions sound an attractive alternative to the use of conventional 'blunt' trade sanctions, in practice, they face a number of technical difficulties. Claude Bruderlein, commenting on Interlaken[83] in a review of the process noted, "Such sanctions require blocking not only the movement of assets into and out of the targeted country, but necessitate also the freezing of all assets managed for the benefit of the targeted country all over the world. Given the fungible nature of financial assets, their propensity to be moved around the world in a matter of seconds, and the various possibilities to conceal the true identity of the owner, the imposition of financial sanctions involves a dramatic expansion of the reach and capacity of sanctions regimes."[84] Amongst the problems he highlighted were difficulties in gathering information on the targeted country's economic and financial profile and an analysis of its vulnerabilities; difficulties in establishing a list of targeted individuals and entities; the role of money and off-shore centres; and the institutional requirements for imposing financial sanctions and the need for technical assistance.

Information Gathering

74. Whereas comprehensive economic sanctions need only limited knowledge about the target, targeted financial sanctions significantly increase the need for qualitative information and analyses of the target's financial and economic profile[85] a point reiterated by the officials from the UK Treasury, "you need to be able to identify assets. If somebody has concealed the identity of those assets, you will not be able to freeze them."[86] In this respect, targeted financial sanctions face a number of difficulties. First, the individuals against whom sanctions are to be targeted have to be identified. This might not only include key members of the regime in question, but a range of other individuals working with or for the target including middle-men, front actors and seemingly unconnected third parties.[87] Secondly, once the appropriate targets have been identified, there are a number of ways in which the individuals in question can seek to hide their assets — "In general criminals become more intelligent or become smarter themselves. There is always a game whereby the authorities find ways of identifying assets [and the targeted individuals] find other ways of hiding their assets. That is always happening."[88] Similarly, targeted individuals would rarely hold their assets in their own name. In the case of Angola, the Treasury and the Bank of England were initially unable to freeze the accounts of named individuals due to a lack of information. This was because "the accounts were in the name of the equivalent of John Smith and the UN did not tell us any more details about John Smith, that is where he was born, date of birth, anything else. Where we have in the UK, let us say, 100 accounts in the name of John Smith, you cannot freeze them all. You have to know which one to freeze."[89] Such problems only serve to underline the need for better information-gathering procedures.

75. In the course of our inquiry, the Committee has found that, as a whole, information-gathering procedures to enable the implementation of financial sanctions are limited. One notable exception is the US Office of Foreign Assets Control which has been described as "the best, perhaps only example of a professional and well resourced administration apparatus."[90] Aside from this, the Committee has seen very little evidence of initiatives to improve the ability of states to gather information on the assets of the elites of sanctioned regimes. Jeremy Carver attributed this to the "weakness of internationality." He noted that if you do not have a significant degree of cooperation between authorities, you are not going to be able to make a substantial contribution towards making sanctions effective.[91] Problems involved in the gathering of information, in the context of the UK, are discussed above.

76. Experts at the Interlaken Seminars noted that the UN Secretariat does not, at present, have the specialised expertise, the capacity or mandate to implement such information management[92], a point made again to the Committee by the Treasury in evidence, "In general the UN does not tend to provide much intelligence. They do not have much of a function there. It is down to individual countries to implement the measures using their own resources or their own authorities."[93] Jeremy Carver felt that the UN should have an important role to play, "the UN can and must be expected to deal with sanctions... if you are going to get financial sanctions working, you have to have a single source and that is the UN."[94]

77. The Committee recognises the importance of information gathering in the implementation of sanctions. Financial sanctions will not be viable in the absence of timely and accurate information on the targeted states and individuals. In its review of sanctions, the Government fails to address the issue of information gathering. We believe that the most appropriate level at which to coordinate and direct financial sanctions is at the international level.

78. However, at present, the UN Secretariat lacks the ability to gather the necessary information and the quality of national reporting to individual sanctions committees is poor. We consider it totally unacceptable that there is no individual or organisation within the United Nations with overall responsibility for targeting financial sanctions, for example against those who continue to enrich themselves while their people suffer. We recommend that the United Kingdom argue and gather support for the establishment of a properly staffed and financed sanctions unit within the United Nations to receive and coordinate information on financial sanctions enforcement and to press national governments to implement such financial sanctions promptly and effectively, in line with UN resolutions. In addition, an Office of Foreign Assets Control, on similar lines to that in the USA, should be set up in the United Kingdom.

The Role of Off-Shore Financial Centres

79. A further problem in gathering information on financial assets held by targeted groups or individuals is the culture of secrecy in the banking system and the lack of jurisdiction of the investigation authorities in some localities. Obviously, financial sanctions would only apply to assets held outside the targeted states. Sanctions are primarily instruments of isolation and the international community would have no jurisdiction to seize assets held domestically. In practice, assets are more likely to be held in certain (mainly OECD) countries where they are more likely to attract competitive rates of interest. As an example, if Saddam Hussein's assets were held entirely in Iraqi currency, then its overall value would have been reduced by over 600,000 per cent.[95]

80. In discussion of possible difficulties in the application of financial sanctions, Switzerland has often been singled out as it is not a member of the United Nations and is, therefore, not subject to UN Security Council Resolutions. In evidence, representatives from the Treasury disagreed: "Although the Swiss are not members of the UN, they voluntarily introduced their own legislation to track the UN legislation."[96] In general, Switzerland has been keen to pursue the idea of financial sanctions for example by initiating and sponsoring the Interlaken process. Jeremy Carver said, "My own experience of the Swiss law is that it is clear, clean; the Department of External Economic Relations has been very effective in policing it."[97] Elsewhere, participants at Interlaken noted that whereas some off-shore centres were being strict in the implementation of financial sanctions and anti-money-laundering measures, others were not. They identified a number of factors influencing the ability of off-shore financial centres to act as loopholes for the evasion of financial sanctions including the regulatory environment and the clarity of resolutions in identifying assets.[98] The experts noted that financial assets were not technically maintained in the offshore centres themselves, but in corresponding hard currency bank accounts in a few of the world's major financial centres, making them accessible for monitoring and control.

81. The Committee recommends that the Government, in its response, include an assessment of the implication of off-shore financial centres for the implementation of financial sanctions regimes.

Seizing Hidden Assets

82. In the course of its inquiries, the Committee has heard evidence that a major impediment to the implementation of financial sanctions has been the identification of specific individuals involved in a particular regime that is subject to sanctions. For example, in the case of the sanctions imposed on Iraq, members of Iraqi opposition groups stated that the regime had "stashed away money" from a tax imposed on oil production in the 1970s in various accounts. They had calculated "that in early 1991 the money with interest would have amounted to $31 billion. This has been disbursed among various companies. We tried to initiate an investigation into it and lost the thread... We have monitored the funds going round the world... beginning with Tunisia, Yemen, Afghanistan and various other places. To give you a small anecdote, the day before the Iraqi Ambassador to Tunisia defected two years ago a messenger arrived with a diplomatic bag in the shape of a black bin bag that contained $3 million which had arrived from Brussels. Saddam does have funds outside the country. This goes round in bin bags, diplomatic bags and whatever other bags he can lay his hands on. We would do very well to try and trace those funds and freeze them."[99]

83. In the UK, under the Trading with the Enemy Act 1914, the Government has the power to seize enemy assets for the benefit of national claimants who have suffered loss by reason of what the enemy has done to them.[100] In the case of Iraq, a UN resolution was passed enabling the Security Council to make use of frozen Iraqi assets.[101] Whilst, to date, the Government has frozen some $739 million in Iraqi assets, the Committee has heard very little evidence of any efforts being made to identify and seize hidden Iraqi assets such as those described by the Iraqi opposition groups.

Institutional Requirements for Imposing Financial Sanctions

84. Another problem identified by the Interlaken seminars is the trade-off between transparency and effectiveness. In the case of UN sanctions, the Security Council never imposes sanctions immediately; there is always debate that will forewarn transgressor regimes that sanctions may be applied. There is, moreover, a feeling among some UN member states that target states should, as a matter of principle, be warned before sanctions are imposed.[102] The net effect is that regimes under threat of sanctions will have time to withdraw any assets liable to be frozen before sanctions are implemented.

85. A further problem is the language of UN sanctions resolutions. A paper submitted by the Netherlands to the Interlaken Seminar notes that the language of UN Resolutions is often ambiguous and unclear due to the understandable process of political compromise. It gave several examples of cases where the Netherlands had had difficulty in implementing resolutions as a result of this ambiguity. In response to this criticism, the Second Interlaken Seminar on Targeting UN Financial Sanctions has produced a "Draft Model or Framework Law" designed to "enable immediate implementation of measures without delay (immediate action often being a prerequisite for effective financial sanctions)."[103]

86. The Committee welcomes the work of the Interlaken Seminars in elaborating a model law for the implementation of UN financial sanctions. In its response, we recommend that the Government give details of what, if any, aspects of United Kingdom law need to be changed to bring it into line with the Interlaken model law on the implementation of UN financial sanctions.

Technical Assistance

87. Another difficulty is the lack of capacity of some member states to implement financial sanctions. This is a problem compounded by the lack of a legislative base for the implementation of Security Council Resolutions. Jeremy Carver said, "It is remarkable how few states have equipped themselves with this basic "tool" of UN membership; and find themselves in constitutional difficulty in giving effect to their international obligations."[104] He stated that very few UN member states had put in place "specific enabling legislation allowing the state concerned to give effect to decisions of the Security Council by means of secondary legislation"[105]; a point he reiterated in evidence — "One of the most dismaying things I discovered when I started to work on sanctions in August 1990 was the appalling patchwork of inadequate domestic laws to translate the international obligations down to domestic level. We have a United Nations Act, the 1946 Act, which is very good, clean and simple and it works... There are only twelve other countries that have comparable legislation... three of the other European nations that have comparable legislation have done so in the past eight years as a result of finding that it is impossible to give effect to these sanctions regimes on the basis of their supposedly self-executing domestic law."[106]

88. Given the fact that few countries have the necessary legislation to implement adequately UN sanctions, it is also unsurprising that very little seems to have been done to develop the capacity of countries to implement and enforce financial sanctions. The Committee was told in evidence by the Treasury and Bank of England that "we have been providing guidance and assistance to our Crown dependencies and overseas territories to help them implement the current measures but not to other independent countries."[107]

89. We recommend that there be a concerted international effort, sponsored by the United Nations, to introduce by a target date in all countries the necessary legislation for the implementation of UN sanctions regimes, including financial legislation. For developing countries, donors should consider how they can assist in this important aspect of capacity building.

Financial Sanctions — The Need for Executive Action

90. The ODI Seminar on Smarter Sanctions concluded that, whilst potentially useful, smarter sanctions would not be sufficient, in their own right, to force governments into compliance with international demands, but rather that they should be used as an additional tool of leverage to other targeted goods and services. Claude Bruderlein agreed, "they offer additional valuable tools to demonstrate the determination of the international community and to support a growing sense of individual accountability of the targeted elite for the unlawful acts of states by seeking control over their financial assets and transactions. Financial sanctions are not a stand alone measure. The targeting of sanctions must be integrated into an overall strategy to induce political changes within targeted states, and be part of other targeted measures such as arms embargoes, visa restrictions, travel restrictions etc."[108]

91. The Committee believes that although serious difficulties remain in the tracking of financial transactions and location of financial assets, targeted financial sanctions appear to be workable. It is apparent that major efforts will need to be expended to ensure that the international community as a whole, and individual member states in particular, acquire the necessary technical expertise to implement and enforce such sanctions.[109]

ARMS EMBARGOES

92. If a state is judged to have violated norms relating to international peace and security then it stands to reason that that state should be deprived of the means of waging war. To this end, arms embargoes have been imposed against a number of countries by the UN, EU and OSCE in addition to ad-hoc regional arms embargoes and export controls exercised by individual nation states. Arms embargoes are now becoming widely used by the Security Council as a response to crises. In its first 45 years, the UN called for mandatory arms embargoes only twice: against Rhodesia and South Africa. In the past decade however, it has done so on ten occasions. It is not our intention in this Report to examine arms embargoes in detail. Many of the issues have been discussed in our previous Report on Conflict Prevention and Post Conflict Reconstruction. We commented there on the linkages between arms exports and conflict in developing countries. We have also recommended that the Government take steps to regulate the activities of arms brokers, to improve end-use controls and to press for similar measures to be implemented across the EU.[110] These issues are also being examined by the Select Committees on Defence, Foreign Affairs, International Development and Trade and Industry in the course of their inquiry into the Government's Reports on Strategic Export Controls.

93. Ambassador Fowler, Chair of the UN Sanctions Committee on Angola observed, "the UN does many many things, some of them well, some of them not at all well and those it does not do well, it does not do well because its member states are not committed to seeing it do that. Why has the UN not fixed many of these problems we are talking about in Africa? It is because we, the member states, have not given it the wherewithal to do so and because frankly we have not been that interested in seeing those things occur.[111] Referring to the case of Angola, he noted "Savimbi has earned between US$3 and US$4 billion from his diamond marketing over the past eight years. That buys an awful lot of military equipment."[112] Jonas Savimbi was reported to be receiving between five and seven supply flights each evening. "His part of Angola is landlocked. It is not easy to get 50-tonne tanks into that part of Angola, yet he does that. We might usefully concentrate on how he does that."[113]

94. The United Nations Association of Great Britain and Northern Ireland agreed, "if a ban on arms sales to the offending government is imposed, private dealers — and some governments — wittingly and speedily defy the ban. The sophisticated weapons still possessed by Jonas Savimbi's UNITA group in Angola is stark evidence of UN sanctions being flouted."[114]

95. Ambassador Fowler stated that "there is no doubt that these very sophisticated weapons are not made in Africa. They are being sent to Africa from all kinds of points with all kinds of middlemen who may have nothing to do with the country of origin of the equipment. We have to cast the net pretty widely if we are going to stop Savimbi from being able to wage war."[115]

96. Ambassador Fowler accepted that it would be nearly impossible to stop the illegal exports of diamonds and imports of arms and munitions, "I do not think I can stop, no matter what we do, no matter what the panels do, no matter how much convincing we do of governments, I am not going to stop Monsieur Savimbi from selling diamonds. What we hope we can do is make it more difficult. Above all we can make it more expensive, in other words he will get less money for it. We can force him into grey and black markets. We can force him away from more regulated, more lucrative markets like London, maybe Antwerp, into more popular markets which will give him less for his stones... Let us make it less profitable. Exactly the same thing on the arms side. The arms trade is such that there will always be people willing to sell these things to people. The issue is the price: the price of the arms and the price of the transport to get them in there. What we hope to do is force both of those up, make him pay much more for what he gets and make it much more difficult and much more expensive for him to get it."[116]

97. We reiterate our recommendations made in previous reports that the Government tighten controls on arms brokers and introduce end-use controls and push for similar measures to be adopted throughout the EU.

SANCTIONS COMMITTEES — ENFORCING SANCTIONS

98. The failure to enforce effectively the sanctions regime against UNITA is a scandal which must be urgently addressed by the international community. A number of witnesses have also commented on the enforcement of sanctions in general. For each sanctions regime, the Security Council establishes a sanctions committee. Sanctions committees are composed of representatives of the 15 members of the Security Council, generally chaired by a non-permanent member of the Council, and are invested with the authority to monitor and implement sanctions regimes.

99. The Committee has heard that, by and large, the committees have remained somewhat passive in the monitoring and enforcement of arms embargoes, being content to receive information on violations provided by governments on a voluntary basis. For example, the summary of an April 1997 meeting by the chairs of the Security Council sanctions committees noted that "certain committees" were "practically non-operational and certainly inefficient...In fact...four are not deploying any substantial activity."[117] A major problem faced by sanctions committees is a lack of administrative capacity. Ambassador Fowler, chair of the Sanctions Committee on Angola, told the Committee, "I have about one third of a person in the UN Secretariat who helps me arrange meetings. My own expenses are paid by the Canadian Government."[118] A further problem is a reluctance on the part of national governments to provide timely and accurate information to sanctions committees on breaches of sanctions regimes. Ambassador Fowler accepted that the quality of national reporting to UN sanctions committees was "variable"[119], a point reiterated by Peter Hain, who noted that Ambassador Fowler was "extremely frustrated not just with the question of UN resources behind him but more with the lethargy there has been internationally on behalf of the very same governments who vote for Security Council resolutions empowering him, amongst others, to take action against UNITA actually to come forward with the intelligence, the action to stop supplies coming in and the diamonds going out... until I actually asked the Foreign Office for a real priority to be given to this I think that there was a sense that life is moving along, we are getting what we can and I know Ambassador Fowler felt that he had not had the cooperation of neighbouring African governments who I think on the one hand vote for resolutions and on the other hand some of their officials and their business and their transport operators are meanwhile providing the very fuels and munitions which Savimbi depends upon."[120] Since that time, the Minister has provided further details on this issue. In the House of Commons on 18 January 2000, Peter Hain stated, "It is vital that private individuals and companies engaged in breaking the law by deliberately breaching UN sanctions on UNITA are stopped. I can inform the house that we are referring to the UN sanctions committee today, and its expert panels, the details of three such individuals, which we hope that they will be able to follow up."[121]

100. We are concerned that, as a whole, the quality of national reporting to sanctions committees remains low, thereby reducing the effectiveness of sanctions regimes. We welcome the Minister's assurances that the Government will be giving an extra priority to intelligence gathering in regard to sanctions regimes imposed by organisations of which the UK is a member. We request details of the further action, procedures and resources dedicated to intelligence gathering with regard to sanctions regimes. The UK, as a permanent member of the UN Security Council, has an important role to play in encouraging other member states to be more active in the monitoring and enforcement of UN sanctions regimes.

101. In an effort to combat sanctions-busting, Ambassador Fowler had, on the authorisation of the Security Council, established two expert panels, "The first focussing on where Savimbi gets his money, looking principally at financial transactions, diamonds and how he gets his oil. The second panel of four experts to look at where he gets his war materiel and how he gets it into his country."[122] The Government, in evidence, was very supportive of the initiative, as Tony Faint, Director, Balkans Division, DFID, explained, "From the point of view of DFID, I think this is quite an interesting sort of test case for us, of the ability to design smarter sanctions which are well targeted and do not have adverse humanitarian effects."[123] Since that time, the Committee has heard that, at a meeting on 26-27 August, it was decided that, for administrative purposes, the two panels would, in effect, operate as one panel under the chairmanship of Ambassador Mollander of Sweden. The UK was, at the time of writing, in the process of authorising the payment of $200,000 towards the establishment and running costs of the panels.[124] The Committee very much welcomes the initiative of Ambassador Fowler in establishing the expert studies and commends the Government for supporting the initiative. This does not address, however, the more general problem of the lack of capacity of the sanctions committees to monitor and enforce sanctions regimes effectively. The UN must provide the human and financial resources necessary for the sanctions committees to do their jobs properly. We also ask the Government, in its response, to spell out what proposals it is putting to the UN to improve the capacity of sanctions committees. In addition to improving the capacity of sanctions committees, there is also a need to improve the capacity of countries surrounding a targeted state to monitor and restrict cross border trade in prohibited goods and services.

FLIGHT SANCTIONS

102. The German Government has recently taken an initiative in examining the potential for arms embargoes and travel sanctions by sponsoring an expert conference on the issues organised by the Bonn International Centre for Conversion.[125] Whilst the initiative is still in its early days, we trust that the Government will actively support and participate in the German Government's attempt to elaborate what has been described as "the next step" of smarter sanctions: arms embargoes and travel sanctions.

INDIVIDUAL RESPONSIBILITY

103. Whilst the focus of this Report is on the future of sanctions in the sense of instruments of isolation as set out under Article 41 of the UN Charter, the Committee has, in previous reports addressed other issues which relate more broadly to sanctions policy. One such issue is the concept of individual responsibility. In our Report on Conflict Prevention and Post Conflict Reconstruction we noted that "in reducing the risks of conflict an important factor must be removing the culture of impunity which allows war lords, political leaders and their followers to believe that they can get away with human rights abuses and the breaking of humanitarian law. Punishment for such war crimes is also a necessary component of a post-conflict society coming to terms with its recent past."[126] We also lamented the Government's failure to ratify the Statute of the International Criminal Court, recommending that legislation be brought forward in the current session to ensure its ratification. Since that time, the Government has announced the publication of a draft Bill to "give effect to Britain's support for an international criminal court."[127] We welcome the publication of the draft Bill to ratify the United Kingdom's commitment to the international criminal court. We trust that the Bill will be included in the legislative programme of the next session to ensure that the United Kingdom is one of the first 60 states to ratify the agreement so as to bring it into force.

ACCESS TO INTERNATIONAL FINANCE AND GRANTS IN AID

104. Another possible sanction (in the broader sense of the term) is the withdrawal or suspension of development assistance. Claude Bruderlein stated in evidence that "the restriction of bilateral aid is not a sanction per se. Every country is free to decide to whom it will give its assistance and aid. Therefore it is not clearly under the sanctions or the collective response to the threat to international peace and security."[128] At the same time, developing countries often depend on development assistance for a considerable proportion of their budgets and, whilst development assistance is obviously discretionary, its unanticipated withdrawal can often have a similar or greater impact to sanctions proper as was the case in Burundi. Gregory Salter, commissioned to write a report on the sanctions imposed on Burundi, noted that "the sanctions against Burundi had their major economic impact through the resulting de facto freeze on donor financing in the country, and the consequent escalation in internal debt and external debt arrears. Indeed... Burundi has suffered more from reduced access to international funds than from the embargo itself."[129]

105. In evidence, Save the Children also expressed concern about the use of aid as a sanction, drawing the Committee's attention to aid embargoes on Zanzibar and Sudan, which had experienced problems "tantamount to sanctions."[130]

106. In its White Paper on International Development, DFID states that "there will be some circumstances under which a government-to-government partnership is impossible, because the government concerned is not committed to the elimination of poverty, is not pursuing sound economic policies or is embroiled in conflict." It goes on to state that "where poor countries are ruled by governments with no commitment to helping the poor realise their human rights, we will help — where we can do so — through alternative channels. These will include the institutions of civil society, voluntary agencies and local government. In such cases our assistance will be tightly focussed on the victims of neglect and oppression."[131]

107. Since the Committee announced its inquiry into the future of sanctions, the Department for International Development has suspended development assistance to both Serbia and Pakistan. In the case of Pakistan it stated, "We are deeply concerned at the situation in Pakistan: widespread corruption, economic mismanagement, increasing poverty and now military rule... Obviously, we cannot provide development assistance to the military authorities in Pakistan. No new funds for programmes linked to governmental institutions will be made available and all our specialists who have been advising the Government have stopped work."[132]

108. In the context of another inquiry, the Committee has taken the opportunity to question the Secretary of State for International Development on the suspension of aid to Pakistan. She acknowledged that decisions to suspend aid programmes were fraught with difficulties, "it is quite popular for people to call for a cutting off of aid when something oppressive happens, but by and large I think that is the wrong response. It is to punish the poor for the misbehaviour of their government... I do not think the assumption should be that when people are suffering even greater oppression you pull away from them... because of course the people with bad governments are the most oppressed of the earth... I think it is wrong to see aid as the weapon of political punishment. It is funds that belong to the poor of the earth and that should be used whenever possible to relieve and improve their condition and there are other sanctions that are available to governments. But it is popular with those not engaged in development to say: "Oh, stop aid", because that is painless for commerce, painless for other kinds of sales, because the poor get hurt."

109. The sudden withdrawal of development assistance can often have a similar or greater impact to the use of traditional sanctions. Full consideration should be given to the humanitarian/developmental impact of withdrawing government-to-government development assistance.

110. The Committee requests that the Government provide the Committee with details of all countries to whom it has suspended development assistance for political reasons. This list should be updated annually in the Department for International Development's Departmental Annual Report.

111. Development assistance can also be used strategically as an incentive to improve governance, human rights and the pro-poor policies of a given government. This is an approach that has been developed by the Department for International Development in its use of 'development partnerships'. The White Paper states, "Where low income countries are committed to the elimination of poverty and pursuing sensible policies to bring that about, the Government will be ready to enter a deeper, long-term partnership and to provide: a longer term commitment; an enhanced level of resources; and greater flexibility in the use of resources."[133] Partner governments are expected to "pursue policies which promote responsive and accountable government, recognising that governments have obligations to all their people; promote the enjoyment of civil, cultural, economic, political and social rights; and which encourage transparency and bear down on corruption."[134]

112. The Committee welcomes DFID's use of development partnerships to encourage good governance, respect for human rights and the elimination of corruption.

Humanitarian exemptions

113. The second strand to the concept of smarter sanctions is to improve the means by which humanitarian goods and service are exempted from sanctions regimes so as to minimise the human cost of sanctions. At present, all UN sanctions resolutions contain provisions to exempt certain goods such as food and medicine though these are not always clearly defined. However, in the course of this inquiry, witnesses have drawn attention to a number of weaknesses in the current system of humanitarian exemptions. These include: decisions relating to dual-use goods — that is to say, goods that could have both a civilian and a military application; the means by which humanitarian exemptions to sanctions are processed; and the scope and definition of humanitarian exemptions.

114. The question of the definition of humanitarian assistance was raised by Peter Hain in evidence to the Committee in relation to the Oil Embargo imposed on the Federal Republic of Yugoslavia. On 23 April 1999, the Council of the European Union adopted Common Position 1999/273/CFSP imposing a ban on "the sale of petroleum and certain products to the Federal Republic of Yugoslavia." A revised Council Regulation of 1 October 1999 stated that "the competent authorities may authorise on a case-by-case basis... the sale, supply or export of [certain] products if conclusive evidence is given to these authorities that the sale, supply or export serves strictly humanitarian purposes."[135] Since that time, a further Council Regulation[136] has allowed for the sale of petroleum and petroleum products to two municipalities in the Republic of Serbia under the "Energy for Democracy Programme" — the cities of Nis and Pirot. The Committee raised this issue with the Minister of State who stated that the exemption was "specifically to provide heating oil and energy assistance because we are very well aware of the freezing winter setting in and also of the fact that those areas are opposed to Milosevic's brutal rule. That is a clear example where we are able to address humanitarian relief where we can but also there is, as it were, an advantage in being opposed to a dictator's brutal policies."[137] He went on, "It is a humanitarian effort but we are able to deliver it because of the added opportunity of a political bonus and a political factor too in that we are not giving support to Milosevic and the regime that surrounds him; we are actually rewarding those who are opposed to his brutal rule."[138] He later accepted that "the world is a messy place and sanctions need to be applied and exemptions organised in a way that allows us to maximise humanitarian relief whilst at the same time achieve the change which ultimately will be for the benefit of people in humanitarian terms of getting rid of oppressive policies or changing them in some final way, then that is something to be welcomed."[139]

115. Dennis McNamara, UNHCR Special Representative to the Balkans, was in no doubt as to the humanitarian importance of heating oil when questioned by the Committee, "If we are going to get these refugees and displaced persons through the winter they have got to have heating both in Kosovo and maybe even more so in Serbia in view of the damage to infrastructure so for us the humanitarian consequences will be the same whatever label is used and our plea has been do not let us have another humanitarian catastrophe in this region by denying essential utilities and services that particularly the vulnerable displaced populations are going to need."[140] This view was reinforced by an OCHA assessment of energy needs in the Federal Republic of Yugoslavia and of predicted winter shortages and recommended humanitarian measures.[141] Similarly, in the case of Iraq, it has been argued that health requirements should go beyond medicines to include improved infrastructure in the areas of water and sanitation and electricity for healthcare facilities.

116. The Committee has, in a previous report, remarked on the importance of the distinction between humanitarian and development assistance. In that report, we stated that "It is accepted that a government might not want to give funds to a certain country because it considers the politics of that country to be unacceptable or its practices corrupt. Humanitarian assistance, however, is meant to find its way, when required, even to such places. It is a response to abject human suffering and, as we have emphasised above, it is provided neutrally and impartially."[142]

117. We believe that the provision of oil — described as humanitarian by the Minister — solely to municipalities controlled by opponents of Milosevic serves to undermine fatally the impartiality and neutrality of humanitarian assistance. It is one thing to support principled humanitarian aid but quite another to use the risk of diversion as an excuse to supply such assistance solely to one's political allies.

118. More generally, we agree with the views of Dennis MacNamara and others on the danger that the definition of humanitarian, as opposed to developmental, assistance is too tightly drawn. The result is an effective embargo on what are in fact humanitarian requirements.

119. However, just as too narrow a definition of humanitarian assistance can have dire humanitarian consequences, so too can inappropriate humanitarian assistance. For example, a report commissioned by Save the Children discovered that the universal food ration, introduced in Iraq as part of the Oil for Food Programme, had had a negative impact on certain enterprising groups, especially farmers. The report states, "the ration has resulted in the dramatic collapse of prices of key agricultural products, which were the mainstay of the economy. The prices of all ration items (flour, rice oil, chickpeas, lentils, sugar, tea and soap) have dramatically fallen. By far the most critical repercussions concern the extremely low price of wheat which is now selling at well below the cost of production."[143] This point was raised again in oral evidence. Chris Saunders, Programme Officer, Middle East, for Save the Children noted, "If we could see local purchase of foodstuffs in the north [of Iraq] we would see a burgeoning agricultural sector. As it is because foodstuffs are imported under [Resolution] 986 the agricultural sector has declined because it is not worth growing."[144]

120. The "dumping" of humanitarian assistance which undermines local production, is unacceptable and should have been avoided through prior impact assessments. In previous reports, we have underlined the importance of local procurement and employment in the provision of both humanitarian and development assistance.[145] The humanitarian response to the imposition of sanctions must take account of local procurement and of the local economy in the provision of humanitarian assistance.

121. One of the conclusions of the ODI seminar on smarter sanctions was that the success or otherwise of humanitarian exemptions will depend on a more specific vulnerability analysis.[146] The Committee agrees (and had already noted — in the case of the South/Centre of Iraq) that a lack of information is a major impediment to the development of a successful regime of humanitarian exemptions. Whilst recognising that there may be political imperatives for the swift imposition of sanctions, impact assessments should be undertaken as soon as is practicable after any sanctions regime is fully implemented by those with relevant expertise from UN agencies and non-governmental organisations. Sanctions regimes must take account of issues such as the level of economic development in the country targeted and groups that are likely to be disproportionately affected by the imposition of sanctions. Furthermore, sanctions regimes should be sufficiently flexible so as to allow for fine-tuning in response to any unforeseen adverse humanitarian consequences.

SANCTIONS COMMITTEES — HUMANITARIAN EXEMPTIONS

122. We have commented previously (paras 99-102) on the role of sanctions committees in enforcing sanctions. The Committee has also heard a number of criticisms of the role of sanctions committees in processing humanitarian exemptions to sanctions — both in general and in relation to specific regimes.

123. A number of these criticisms were summarised at the ODI seminar on smarter sanctions, "The current Ad Hoc sanctions committees are staffed by diplomats, not always with the required technical expertise. The staff also rotates as a function of the governments sitting on the Security Council. There is no institutional memory of sanctions policy and practice. The deliberations are not transparent, the sanctions committees not accountable. It is held that sanctions committees focus too much on humanitarian exemptions as a potential threat to the effectiveness of sanctions."[147] A similar point was made in evidence by Rita Bhatia of Save the Children, "[Sanctions committees] are made up of representatives of the 15 members of the Security Council. One of the problems is that... these individuals are often diplomats, they are not technical people, and also there are difficulties in using experience from one sanctions committee and transplanting that to another one, so there is loss of the institutional learning... one of the clear criticisms with the Sanctions Committee on Iraq is that a lot of the processes have become politicised... Earlier on in the programme, 46 per cent of all items were put on hold and only that committee member [that put the item on hold] can release that item."[148]

124. The Secretary-General of the United Nations, Kofi Annan has also expressed concern about delays in the approval of applications by the Sanctions Committee on Iraq. In particular, he referred to "the growing number of holds placed upon applications and the resultant serious implications for the implementation of the humanitarian programme."[149] According to a recent UN report, 23.7 per cent of applications for the import of goods under Phase V of the Oil for Food Programme had been placed on hold, including 100 per cent of applications for telecommunications, 65.5 per cent for electricity, 53.4 per cent for water and sanitation and 43 per cent for oil spare parts and equipment.

125. One set of practical proposals for improving the efficiency and effectiveness of sanctions committees was made by Ambassador Amorim from Brazil, in a note by the President of the Security Council entitled "Work of the Sanctions Committees."[150] A number of witnesses have referred to this document and, broadly speaking, have concurred with its recommendations. Whilst the document contains some 20 recommendations, witnesses have, in particular, pointed to the recommendations aimed at improving the effectiveness of sanctions (discussed above under arms embargoes) and measures for streamlining humanitarian exemptions.

Streamlining Humanitarian Exemptions

126. The note by Ambassador Amorim makes three proposals for streamlining the exemption process for humanitarian supplies

(a) "UN Agencies as well as humanitarian organisations and other relevant organisations should benefit from special, simplified procedures in requesting humanitarian exemptions, in order to facilitate the implementation of their humanitarian programmes;

(b) "Consideration should be given to how humanitarian organisations could have the possibility to apply for humanitarian exemptions directly to the sanctions committees; and

151

127. The Committee endorses the findings of the Note by the President of the Security Council on the Work of the Sanctions Committees and recommends that a standing list of life-saving supplies be agreed, in consultation with national, international and non-governmental providers of humanitarian aid, for exemption from sanctions regimes.

128. Save the Children confirmed that they had experienced problems with the Sanctions Committee on Iraq. Whilst they agreed with the note by Ambassador Amorim, they argued that "this note perhaps does not go far enough. It does not make humanitarian assessments mandatory."[152]

129. Throughout the course of this inquiry, the Committee has heard a great deal of evidence on the inadequacies of the existing procedures for exempting humanitarian goods and services from sanctions regimes. The UK Government has, in part, acknowledged this and, in a draft UN Resolution (which was adopted by the Security Council on 17 December 1999) has allowed for a list of humanitarian items, including foodstuffs and medicines, that will no longer require to be submitted to the Sanctions Committee for approval.

130. Claude Bruderlein, in his memorandum to the Committee, made a number of recommendations to ensure an integrated approach to exemption mechanisms. He reflected the recommendations of Ambassador Amorim by suggesting that the Chair of the sanctions committee should visit the region in question to gain a first hand perspective on the humanitarian situation and also recommended that committees should request regular updates of the assessment provided by the Secretariat in order to ensure the adequacy of its approach on exemptions. Moreover he stated that "Sanctions committees should decide on institution and country specific items which should be exempted from the sanctions regime...humanitarian organisations that should benefit from institution-based exemptions include members of the UN system, their non-governmental implementing partners, and international members of the ICRC and IFRC. Country specific exemptions should take into account the specific nature of each crisis and country and include foodstuffs that are staples of vulnerable groups."[153]

131. The Committee further recommends that other means of expediting the delivery of humanitarian goods and services be considered including institutional exemptions for members of the UN system, their non-governmental implementing partners, and international members of the ICRC and IFRC, coupled with increased end-use monitoring.

POST-SANCTIONS RECONSTRUCTION

132. Another major concern is the long term humanitarian/developmental consequences of sanctions. As the ODI Seminar on Smarter Sanctions found, "The transformation of a legal economy into a black-market economy and the social [and intellectual] costs resulting from sanctions are not simply reversible when sanctions are lifted."[154] Furthermore, sanctions can undermine the domestic opposition to the target regime and the longer-term foundations for a more democratic culture.

133. The Quakers stated in evidence to the Committee "that whenever sanctions are imposed, serious thought must also be given to, and preparations made for a future in which they have been lifted. The end goal of sanctions, as with any enforcement measure, must be the return of the people in question to the international community, and the building of trust and relationships strong enough to prevent the recurrence of destructive behaviour or violent conflict in the long term."[155] The Committee agrees that whenever sanctions are imposed, serious thought must also be given to, and preparations made for, a future in which they have been lifted.

134. The long term impact of sanctions is particularly serious in developing countries. ActionAid stated that "The Burundi experience raises important but interesting questions about the assistance role of the major donors and official creditors where regional sanctions have been imposed against a poor country... the sanctions on Burundi had their major economic impact through the resulting de facto freeze on donor financing in the country, and the consequent escalation in internal debt and external debt arrears... Burundi has suffered more from reduced access to international funds than from the embargo itself. Yet, since the suspension of sanctions, there has been only a small increase in international aid to Burundi."[156] Save the Children were particularly concerned about the effects of conditional assistance in the post-sanctions period as donors were seeing to channel their assistance through non-governmental sources asking, in the case of Burundi, whether it was "realistic to attempt to restore functional infrastructure in areas such as health and education if the Government of Burundi does not have the resources to make this work?"[157]

135. The impact of sanctions on society and on infrastructure can be as devastating as the impact of conflict or natural disasters and the international community should be equally prepared to assist in reconstruction. Whilst natural disasters can obviously not be anticipated, the international community will often be able to anticipate the lifting of sanctions either as a result of a change of policy on the part of the targeted regime or as a result of the sanctioning states taking the decision to lift them. Hans von Sponeck, for example, felt that it was important that the international community should prepare for the post-sanctions period in Iraq in advance of sanctions being lifted .

136. The Committee believes that sanctioning organisations have an obligation to ensure that targeted states are adequately reintegrated into the international community once sanctions have been lifted to ensure that the long term humanitarian impact on the population is minimised. We recommend that once sanctions have been lifted donors — bilateral and multilateral — should agree a coordinated strategy for post-sanctions reconstruction similar to strategies developed in the wake of conflicts or natural disasters. We invite the Government, in its response to this Report, to provide the Committee with details of any preparations it is making for the eventual lifting of existing sanctions regimes such as those imposed against Iraq.

Improving the Effectiveness of Sanctions

MONITORING

137. Whilst it is important to ensure that sanctioning states have sufficient information as to the vulnerabilities and humanitarian needs of any targeted state prior to the imposition of sanctions, it is equally important to ensure that there are adequate procedures for monitoring the impact (humanitarian and otherwise) of sanctions once they have been imposed. Mikael Barfod of ECHO noted that there was a lack of effective procedures for monitoring the impact of sanctions, "I think very often these [monitoring] mechanisms are not in place... The monitoring is something that we only hear about second or third hand and that is not satisfactory... ECHO itself has a monitoring system. In fact, we have 70 of our own experts in place in all the various humanitarian crises of the world. These experts monitor very precisely what happens in a sanctions system, whether the humanitarian items get through, whether the needs are covered with what gets through, whether more is needed... I think that system works well for us...but I would like to go a bit further.. I would like our experts to be involved directly in the mechanisms in place, even someone from ECHO head office could go to the Sanctions Committee in New York, why not? We know where the shoe pinches I would have thought so why should we not be involved. Certainly we can also help when it comes to designing sanctions, as has been said many times now."[158] Moreover, major reports commissioned by the UN Department of Humanitarian Affairs published in 1995 and 1997 recommended that humanitarian assessments be conducted before, during and after sanctions have been imposed.[159]

138. The Committee is concerned that, in many cases, existing mechanisms for monitoring the humanitarian/developmental impact of sanctions are inadequate. We recommend that all sanctions regimes should have provision for an ongoing system of monitoring their impact. To this end, use should be made of existing expertise in the field — from UN organisations, ECHO and other governmental and non-governmental organisations.

EXIT STRATEGIES

139. A further suggestion for improving the effectiveness of sanctions is that sanctions should have explicit criteria for determining when they should be lifted. Save the Children stated in evidence, "for sanctions to be justifiable there must be reasonable prospect that their aims can be achieved. There is also a case for laying down precisely defined objectives and termination criteria in future sanctions regimes."[160] At present, UN sanctions remain in force until a decision is taken to lift them. This means, in essence, that a single Permanent Member can prevent their being lifted by vetoing any resolution to that effect. A number of witnesses, including Save the Children, have suggested that sanctions should be time-limited, requiring a "green light" for renewal beyond a specified point.

140. This is especially important given that, according to the United Nations Association, "the member states of the United Nations are very capable of tiring of a crisis and of losing the will adequately to continue supporting those unintended victims as fully as they should. Iraq is one such example. The civilian population has not been adequately supported throughout the eight years during which the post-Gulf sanctions have been in operation."[161] The UNA agreed with other witnesses that "sanctions should only ever be imposed for a limited period, even if they need to be extended. Full and proper review should be undertaken regularly and the type of sanctions used should change if a particular situation demands this." The UN General Assembly, in 1997, called for the progressive lifting of sanctions as an inducement to compliance.[162]

141. The Committee agrees that serious thought must be given to exit strategies from sanctions regimes. The Committee requests that, in its response to this Report, the Government provides an assessment of the merits of placing a time limit on the application of sanctions regimes.

67 http://www.smartsanctions.ch Back

68 Ev p.1 Back

69 Q.15 Back

70 Ev p.180 Back

71 See, for example, Ev p.79 Back

72 Ev p.79 Back

73 UN Sanctions: How effective? How Necessary, Andrew Mack and Asif Khan, Strategic Planning Unit, Executive Office of the Secretary-General, United Nations, April 1999 Back

74 Can Sanctions be Smarter?: The Current Debate, Report of a Conference held in London, 16-17 December 1998, p.18 Back

75 Ev p.107 Back

76 Ev p.1 Back

77 Q.454 Back

78 Q.389 Back