CSS Exam Prep Virtual Classroom Session 2 PDF

WELCOME! Pre-Virtual Classroom Assistance 1. Audio help: Use VoiP (computer audio) OR Telephone You can select the audio in the control panel. See ”C” on the right. When dialing in by TELEPHONE, make sure you used both your Access Code (9 digit number) and personal audio pin (2 digit num...

WELCOME! Pre-Virtual Classroom Assistance 1. Audio help: Use VoiP (computer audio) OR Telephone You can select the audio in the control panel. See ”C” on the right. When dialing in by TELEPHONE, make sure you used both your Access Code (9 digit number) and personal audio pin (2 digit number). You can see your personal audio pin in the control panel, under audio – phone option. 2. Mobile access - Attendees can join sessions from iPhone, iPad or Android device. Download the GotoTraining App from Citrix and type in Training ID number. (meeting # is in your confirmation email). 3. At the bottom of the screen please make sure you are on mute (letter “D”) and your webcam is turned off (letter “E”.) GotoTraining Help: Toll-free: (877) 582-7011 or +1 805 617 7370 https://support.logmeininc.com/gototraining/contactus?p=0-0 ACSS helpdesk:[email protected] All rights reserved | ACSS 1 CSS Exam Prep Virtual Classroom Session 2 Imposers and Targets – The International Arena v15 All rights reserved | ACSS 2 Moderator Natasha Bright Association of Certified Sanctions Specialists (ACSS) [email protected] www.sanctionsassociation.org All rights reserved | ACSS 3  Agenda I Welcome and Introductions II United Nations Security Council Sanctions III European Union Sanctions IV Wrap Up and Q&A All rights reserved | ACSS 4  Introduction All rights reserved | ACSS 5  Housekeeping 1. Audio help: Use VoiP (computer audio) or Telephone. Make sure you use your Access Code (9 digit) and then audio pin (2 digit). (marked “C”) 2. Mobile access - Attendees can join from iPhone, iPad or Android device. Download the GotoTraining App from Citrix and type in Training ID number. (meeting # is in your confirmation email). 3. Please make sure you are on mute and your webcam is off. Controls are on the bottom of your screen and marked here as “D” and “E”. 4. Download the slides and materials by clicking on the document icon in your control panel (marked “B”). 5. You will participate in “practice test questions” using the test tool and ”exercises”, using the chat box to submit your answers. These are not counted against you. 6. You can ask questions to the speaker via the chat function. (marked “A”). GotoTraining Help: Toll-free: (877) 582-7011 or +1 805 617 7370 https://support.logmeininc.com/gototraining/contactus?p=0-0 ACSS helpdesk:[email protected] 6 Using the Chat Box What is the weather in your location? Share your answer with the group using the chat box. All rights reserved | ACSS 7  Martijn Feldbrugge Scott Nance Speakers Director Business & Sanctions Consulting Network Principal Langley Compliance Consulting LLC web: www.bscn.nl [email protected] email: [email protected] All rights reserved | ACSS 8  UN Security Council Sanctions - Overview and Legal Foundation All rights reserved | ACSS 9  Legal Foundation: UN Charter The ability of the UN to impose economic sanctions is contained in the UN Charter, the legal document that founded the UN. Article 41 of the Charter: The Security Council may decide what measures not involving the use of armed force are to be employed to give effect to its decisions, and it may call upon the Members of the United Nations to apply such measures. These may include complete or partial interruption of economic relations and of rail, sea, air, postal, telegraphic, radio, and other means of communication, and the severance of diplomatic relations. All rights reserved | ACSS 10  Overview of UN Sanctions  Sanctions are an instrument to preserve peace without the need to resort to military force.  Targets of UN sanctions have been primarily countries or individuals that threaten the peace, although the UN has also sanctioned organizations such as Al Qaeda as well. All rights reserved | ACSS 11  Overview of UN Sanctions  The UN has imposed sanctions in at least 31 cases.  The UN currently has 14 programs in effect.  Past and present programs include: Southern Rhodesia, South Africa, Yugoslavia, Haiti, Angola, Liberia, Eritrea/Ethiopia, Rwanda, Sierra Leone, Iran, Côte d’Ivoire, Somalia/Eritrea, , Iraq, the Democratic Republic of Congo, Sudan, Lebanon, North Korea, Iran, Libya, the Taliban, Guinea- Bissau, Central African Republic, Yemen, South Sudan, and Mali.  The UN has also imposed sanctions against ISIL (Da’esh), Al-Qaida, and the Taliban All rights reserved | ACSS 12  Different Forms of Sanctions  UN sanctions encompass a broad range of enforcement options that do not involve the use of armed force.  UN sanctions take different forms, in pursuit of a variety of goals.  Comprehensive economic and trade sanctions  Targeted measures  The UN has applied sanctions to  Support peaceful transitions  Deter non-constitutional changes  Constrain terrorism  Protect human rights  Promote non-proliferation. All rights reserved | ACSS 13  Types of Sanctions Current sanctions methods employed by the UN include:  Travel bans;  Asset freezes;  Arms embargoes;  Bans on trade in certain commodities, such as diamonds, timber, petroleum, and charcoal;  Bans on exports of certain items to the country;  Bans on imports of selected items from the country;  Restrictions on exports to the country of goods and technology related to nuclear, ballistic missiles and other weapons of mass destruction; and  Bans on the export of certain luxury goods. All rights reserved | ACSS 14  Designations The UN designates countries, organizations, or individuals as subject to specific sanctions. What can lead to designation by the UN?  Threats to peace, security or stability;  Engaging in illegal trade in natural  Violations of human rights and international humanitarian law; resources;  Obstructing humanitarian aid;  Violations of arms embargoes;  Recruiting or using children in armed conflicts;  Acts or financing of terrorism;  Targeting civilians including killing and maiming, sexual and  Engaging in or providing support for nuclear, gender-based violence, attacks on schools and hospitals, and weapons of mass destruction and/ or abduction and forced displacement; ballistic missile programs and policies. The result of designation can be:  Sanctions against entire countries (North Korea.)  Sanctions against individuals and entities. The effect of designation is:  The country, organization or individual is placed on the UN’s Consolidated List All rights reserved | ACSS 15  UN Security Council Sanctions: The Process, Committees and Listing All rights reserved | ACSS 16  The Process The Security Council will If passed, the consider a The resolution Resolutions are resolution will The Security resolution will specify subject to veto establish a Implementation Council takes imposing what measures by any one of Committee to by the Member up a “situation sanctions and are to be put the permanent oversee the States of concern.” creating a into place. members. sanctions sanctions program. program. All rights reserved | ACSS 17  Committees and Panels of Experts  The Committees carry out the actual work with respect to a sanctions program.  The committees implement, monitor and provide recommendations to the UNSC on particular sanctions regimes.  Each committee is chaired by a nonpermanent member of the UNSC.  Committees may meet with Member States and international organizations.  Committees typically identify exactly who is subject to sanctions, and what those sanctions are.  In some cases, the resolution creating a sanctions program may identify individuals or groups that will be subject to the sanctions, but in many cases, it is the committee that does so.  Committees may request advice from and meet with Panels of Experts that support the work of the Committee. All rights reserved | ACSS 18  UN Consolidated List Once a person or entity is designated, it is placed on the UN’s Consolidated List https://www.un.org/securitycouncil/content/un-sc-consolidated-list#composition%20list All rights reserved | ACSS 19  UN Consolidated List  Includes all individuals and entities subject to measures imposed by UNSC.  Facilitates the implementation of the measures  Does not imply that all names are listed under one regime, nor that the criteria for listing are the same.  Provided in.xml,.html and.pdf formats.  Member States obliged to implement measures specific to each listed name as specified on the websites of the related sanctions committee, although how they do so differs. All rights reserved | ACSS 20  Implementation  UN sanctions do not automatically go into effect in individual countries.  UN has no independent mechanism for enforcing sanctions.  Sanctions must be implemented by the individual member states.  Most UN members have a process where UN sanctions, including new designations, are incorporated into national law.  This typically requires the enactment of legislation or regulation that adopts the UN sanctions. All rights reserved | ACSS 21  How to Read a UNSC Resolution? 1. Break it up in sections – Preamble / Decisions 2. Distinguish between terms like reaffirms, recalls, urges, or decides. a. Terms like directs, authorizes, and decides may require action 3. You may need to read the previous resolution(s) as well. Use the UN website to find them: e.g. https://www.un.org/securitycouncil/sanctions/1970#current%20sanctions%20measures All rights reserved | ACSS 22 Example – page 1 Preamble All rights reserved | ACSS 23  Example – page 2 Preamble (continued) Here it really starts: All rights reserved | ACSS 24 Example –page 3 All rights reserved | ACSS 25 Example –page 4 All rights reserved | ACSS 26  Your Turn! Exercise Instructions for participants  Download the UN Security Council Resolution 2441 from the control panel.  Read the document  Write in the chat box the answer to the following questions and press “send to organizers” 1. Which UN sanctions regime does this UNSC apply to? 2. Where does the preamble end? 3. What does this Resolution do? Any new measures? 4. Who should comply? All rights reserved | ACSS 27  UN Security Council Sanctions- Delisting All rights reserved | ACSS 28  Delisting Organizations or individuals on the Consolidated List can apply to be “delisted”: removed from the designated list, so they are no longer subject to sanctions There are two separate procedures for delisting: 1. Specific “Focal Point for De-Listing.” 2. Office of the Ombudsman. All rights reserved | ACSS 29  Specific Focal Point for Delisting An individual or entity (except for those on the ISIL and Al-Qaida list) can file an application with the Focal Point for De-listing seeking removal from a sanctions list. Why? To ensure fair and clear procedures for placing individuals and entities on sanctions lists and for removing them, as well as for granting humanitarian exemptions How? UNSC on 19 December 2006, adopted resolution 1730 (2006) by which the Council requested the Secretary- General to establish within the Secretariat (Security Council Subsidiary Organs Branch), a focal point to receive de- listing requests and perform the tasks described in the annex to that resolution. Petitioners, other than those whose names are inscribed on the ISIL (Da’esh) and Al-Qaida Sanctions List, can therefore submit de-listing requests either through the focal point process outlined in resolution 1730 (2006) or through their State of residence or citizenship. The Focal Point also receives requests for exemptions from travel bans and assets freezes exemption requests from individuals and entities on the ISIL (Da’esh) and Al-Qaida and the Taliban Sanctions lists. https://www.un.org/securitycouncil/sanctions/delisting All rights reserved | ACSS 30  Office of the Ombudsman The Office of the Ombudsman to the ISIL (Da'esh) and Al-Qaida Sanctions Committee reviews requests regarding removal from the ISIL (Da'esh) and Al-Qaida Sanctions List of the Security Council's ISIL (Da'esh) and Al-Qaida Sanctions Committee  Independent and impartial Ombudsperson  Appointed by the Secretary-General. https://www.un.org/securitycouncil/node/63489/ All rights reserved | ACSS 31  Practice Test 1 Question 1: The United Nations imposes sanctions: a) Against individuals, entities, and countries b) Against individuals and entities only c) Against countries only Question 2: Which body manages a sanctions regime adopted by the UNSC and typically publishes names to be placed on the UN Consolidated list? a) Political Affairs Office b) Security Council Committee c) Panel of Experts Question 3: Which body reviews requests regarding removal from the ISIL The test tool will (Da'esh) and Al-Qaida Sanctions UN List appear in a moment a) Security Council Committee so you can submit b) Special Focal Point for Delisting your answers c) Office of the Ombudsman All rights reserved | ACSS 32  EU Sanctions- Overview, Objectives and Legal Basis All rights reserved | ACSS 33  Key Objectives of EU Sanctions  Safeguarding EU values, interests and security  Preserving peace  Consolidating and supporting democracy, rule of law, human rights, international law  Preventing conflicts and strengthening international security All rights rights reserved reserved || ACSS ACSS All 34 Common Foreign and Security Policy (CFSP) S All rights reserved | ACSS 35  Legal Basis TITLE IV RESTRICTIVE MEASURES Article 215 1. Where a decision, adopted in accordance with Chapter 2 of Title V of the Treaty on European Union, provides for the interruption or reduction, in part or completely, of economic and financial relations with one or more third countries, the Council, acting by a qualified majority on a joint proposal from the High Representative of the Union for Foreign Affairs and Security Policy and the Commission, shall adopt the necessary measures. It shall inform the European Parliament thereof. 2. Where a decision adopted in accordance with Chapter 2 of Title V of the Treaty on European Union so provides, the Council may adopt restrictive measures under the procedure referred to in paragraph 1 against natural or legal persons and groups or non-State entities. 3. The acts referred to in this Article shall include necessary provisions on legal safeguards. All rights reserved | ACSS 36  Three Types of Sanctions Art. 215 TFEU 1. Sanctions Implementing 2. Sanctions that are more United Nations Security restrictive than provided 3. Autonomous sanctions Council (UNSC) sanctions for in UNSC resolutions All rights reserved | ACSS 37  EU Sanctions: Adoption and Implementation Process All rights reserved | ACSS 38 Overview of main EU bodies All rights reserved | ACSS 39  How are EU Restrictive Measures adopted? Negotiations 1. HR or 1. Proposals by the High Representative (HR), or HR+Commission by the HR and the European Commission Proposed/ Redrafted 2. The Council of the European Union (‘the Council’) passes Legislation into EU law 2.Council of the 3. European 3. The Council informs the European Parliament EU Parliament To Pass: 4. Publication and entry into force Unanimous, or Double majority inform Arms Embargoes and Visa Bans ≥ 55% governments & ≥ 65% EU population are imposed under member states’ own national rules 4. Publication - Entry into force - National implementation All rights reserved | ACSS 40  Council Decision The restrictive measures initially take the form of a Council Decision. The decision will typically contain several elements, including 1) The target of the restrictive measures (the country, individuals, or entities, which are usually identified in an Appendix to the decision) 2) The reasons the measures are being imposed 3) A direction that the Member States “shall take the necessary measures” to implement and enforce the restrictive measures 4) A detailed description of the restrictive measures 5) Any exceptions or exemptions to the measures that may apply 6) The procedure for imposing restrictive measures on additional persons or entities All rights reserved | ACSS 41  Practice Test 2 Q1. Under the EU sanctions regime, sanctions are imposed by a. The EU Commission b. The EU Council The test tool will c. The EU Parliament appear in a moment so you can submit your answers Q2. What are the EU sanctions programs based upon? a. UNSC resolutions, US sanctions and EU amendments to UNSC sanctions b. UNSC resolutions only c. UNSC resolutions/ EU own initiatives All rights reserved | ACSS 42 Implementation at the Member States Regulations implementing sanctions measures are binding and directly applicable throughout the EU All rights reserved | ACSS 43  Short Exercise/Case Study A new sanctions program against country Z is being proposed within the EU. After a positive decision, the sanctions are implemented in the EU, and names of persons, entities and bodies are published. EU Financial Institutions (FI’s) instantly receive hits against the names. 1. What could be the origin of these sanctions? 2. Which EU body will have to decide positively to impose the sanctions? 3. Who will implement the sanctions? 4. Who provides exemptions to the EU sanctions for listed persons, entities and/or bodies? 5. What should FI’s do when they notice circumvention? Submit your answers in the chat box. Please number them. All rights reserved | ACSS 44  Types of EU Sanctions All rights reserved | ACSS 45  Types of EU Sanctions Arms embargoes Travel bans Economic measures Financial measures Next slides will explain these further All rights reserved | ACSS 46  Arms Embargoes Arms embargoes prohibit the sale weapons and related services to restricted individuals, groups, or states. The definition of “arms” is broad. “Arms” include weapons and ammunition, military vehicles and equipment, paramilitary equipment, and spare parts. The definition also includes technical assistance and brokering services related to arms sales; the provision, manufacture, maintenance, or use of arms and related materials; and financing of such transactions. The EU may also impose a ban on the export of equipment which might be used for internal repression. Similarly, the EU may ban the export of dual-use goods, services, or technology when they are intended for military use Taking steps to circumvent an arms embargo is also prohibited There may be exemptions, such as arms supplied to the legitimate government or UN peacekeeping forces All rights reserved | ACSS 47  Travel Bans Travel bans consist of restrictions or prohibitions on travel by designated individuals to the EU. The standard language used is “Member States shall take the necessary measures to prevent the entry into, or transit through, their territories of individuals referred to in” the relevant article of the decision. Members are not required to deny entry to their own nationals. Because the Member States continue to control their own immigration, action by each member is required to implement travel bans. All rights reserved | ACSS 48  Economic Measures: Imports and Exports Economic measures may include a variety of measures, including prohibitions or restrictions on imports and exports of goods and services to countries, entities, or individuals. The most common economic measures are restrictions or prohibitions of imports or exports of goods, services, or technology A total ban on all imports or exports is referred to as an embargo More commonly, though, only specified goods or services are affected Trade restrictions normally prohibit financing, brokering, and insuring trade in the goods as well, as well as services associated with them, such as telecommunications services. Such restrictions may target an entire country, a region of the country, a sector of the economy, or specific individuals and organizations. All rights reserved | ACSS 49  Sanctions on Investment and Transportation A less common type of economic sanction is a prohibition or restriction on investment. These restrictions normally target specific sectors, such as real estate, energy, or nuclear power. Sanctions may also prohibit investment by nationals of the target country in designated sectors of the EU economy, such as nuclear power or arms. Restrictions on investment may apply to the provision of investment services as well. The EU may also impose direct restrictions on trade and transportation, including Prohibiting the use of EU-registered aircraft or vessels for trade with the country. Transit through or export from the EU of goods or services that are not of EU origin Denial of the right of vessels or aircraft from a target country to use EU ports or airports. Prohibiting EU nationals from leasing vessels or aircraft to nationals of the target country. All rights reserved | ACSS 50  Financial Measures Prohibit financial transactions with the target, and may even require the freezing of assets belonging to sanctioned individuals or entities. Council decision will require that “{a}ll funds and economic resources belonging to, or owned, held or controlled by” a sanctioned party must be frozen. The definitions of both “funds” and “economic resources” are broad: “Economic resources” can include practically anything of value, including “‘assets of every kind, whether tangible or intangible, movable or immovable, which are not funds but may be used to obtain funds, goods or services.” Specific examples of funds and resources include: Cash, checks, claims on money, drafts, money orders and other payment instruments; Deposits with financial institutions or other entities, balances on accounts, debts and debt obligations; Publicly- and privately-traded securities and debt instruments, including stocks and shares, certificates representing securities, bonds, notes, warrants, debentures and derivatives contracts; Interest, dividends or other income on or value accruing from or generated by assets; Letters of credit, bills of lading, bills of sale; and Documents evidencing an interest in funds or financial resources. All rights reserved | ACSS 51  Targeted Financial Measures Financial sanctions can target some types of financial transactions specifically. At their widest, sanctions may prohibit all transfers of funds to or from the target country. Sanctions may also limit other types of banking transactions, the provision of insurance and reinsurance, and trade in bonds and equity, as well as transferable securities and money market instruments. An even more targeted type of financial sanctions are so-called “sectoral sanctions,” which prohibit EU nationals from buying, selling, or trading in transferable securities, money market instruments, or equity of certain Russian banks and energy companies. Only the designated types of transactions are banned; all other transactions are legal. All rights reserved | ACSS 52  Freezing and Prohibition to Make Available Sanctions may require that funds and economic resources belonging to or Freezing of funds = controlled by the target be frozen “Preventing any move, transfer, alteration, use of, Frozen funds must be placed in a access to, or dealing with funds in any way that blocked account, and not released would result in any change in their volume, without permission of the relevant national authority. amount, location, ownership, possession, There are specific circumstances under character, destination or other change that would which a sanctioned party may enable the funds to be used, including portfolio nonetheless have access to frozen funds, such as to pay for necessary management.” living expenses. Exceptions are set forth in the decision as well. Freezing of economic resources = Financial sanctions may also prohibit “preventing their use to obtain funds, goods or EU persons from making any “economic resources” available to the services in any way, including, but not limited to, sanctioned party. by selling, hiring or mortgaging them.” All rights reserved | ACSS 53  Licenses The competent national authorities can issue licenses authorizing transactions that restrictive measures would otherwise prohibit. In cases of asset freezes, the authority may allow the release of funds for certain basic purposes, including Meeting basic needs, including food, housing, medicine and medical care, insurance premiums, and utilities; The payment of legal fees; and The payment of certain claims following a decision by a judicial or arbitral authority. National authorities may also authorize other prohibited transactions, such as exports of goods or services, depending upon national law. All rights reserved | ACSS 54  Practice Test 3 Q1. Which of the following best describes the concept of freezing of economic resources under EU sanctions? a. Preventing their use to obtain funds, goods or services, and preventing the entry of the targeted individual into any EU financial institution. b. Prohibiting investment by nationals of a target country in designated sectors of the EU economy c. Preventing their use to obtain funds, goods or services in any way, including, but not limited to, by selling, hiring or mortgaging them. The test tool will appear in a moment so you can submit your answers All rights reserved | ACSS 55  EU Sanctions- Who Must Comply, Targets and Listing All rights reserved | ACSS 56  Who Must Comply with EU Sanctions EU sanctions apply: 1. within the jurisdiction (territory) of the EU 2. on board of aircrafts or vessels under member states´ jurisdiction 3. to EU nationals in any location 4. to companies and organizations incorporated under the law of a member state - including branches of EU companies in third countries 5. to anyone and any company or organization when conducting business within the EU. 1 2 3 4&5 All rights reserved | ACSS 57  Targets of EU Sanctions  Most EU restrictive measures are directed against named individuals and entities.  Entities may include companies, as well as organizations like Al Qaida.  The EU may even direct sanctions against vessels, by “freezing” them, i.e., prohibiting any transactions involving them. All rights reserved | ACSS 58  EU Consolidated List  The “Consolidated list of persons, groups and entities subject to EU financial sanctions” is a full list of the individuals and entities subject to restrictive measures  The Consolidated List can be found at http://data.europa.eu/euodp /en/data/dataset/consolidated-list-of-persons-groups-and-entities- subject-to-eu-financial-sanctions.  Individual Member States may have their own lists in addition to the EU Consolidated List. All rights reserved | ACSS 59  Listing Process A decision of the Council, followed by Publication in the EU Official Journal (https://eur-lex.europa.eu/oj/direct- access.html), and Notification of the target through a letter All rights reserved | ACSS 60  Delisting  Persons and entities on the sanctions list can seek to be delisted by applying to the appropriate committee.  They can also seek legal redress through national courts or the EU Court of First Instance.  While courts can review whether the legal criteria for listing, such as support by credible information, were satisfied, they cannot second- guess the political decision to add a person to the sanctions list. All rights reserved | ACSS 61  Member States Own Lists  Individual Member States may maintain their own sanctions lists  These may include additional names.  Member States may request that particular persons or entities be added to the EU list.  This proposal is typically submitted to, and initially reviewed by, the EU Presidency.  Non-EU members may also request designation.  The request for designation must be supported by credible evidence supporting the request. All rights reserved | ACSS 62  European Union Sanctions: Enforcement and Guidance All rights reserved | ACSS 63  Ownership or Control Entities in which a sanctioned person or entity has an ownership interest of more than 50 percent are also subject to restrictive measures, even if they are not designated separately. The same applies to entities that are controlled by sanctioned persons. Factors indicating control include: Having the right or exercising the power to appoint or remove a majority of the members of the entity’s administrative, management or supervisory body; Having appointed solely as a result of the exercise of one's voting rights a majority of the members of the administrative, management or supervisory bodies of the entity in the present and previous financial years; Controlling alone, pursuant to shareholder agreement, a majority of shareholders' or members' voting rights; Having a legal right to exercise a dominant influence over the entity; Having the right to use all or part of the assets of a legal person or entity; Managing the business of an entity on a unified basis, while publishing consolidated accounts; Sharing jointly and severally the financial liabilities of the entity, or guaranteeing them. https://data.consilium.europa.eu/doc/document/ST-5664-2018-INIT/en/pdf All rights reserved | ACSS 64  Enforcement and Penalties  Enforcement of the EU sanctions regulations is mostly left to the member states.  Sanctions are administered and enforced by the relevant National Supervisory Authority. Different agencies can be involved. Penalties depend on local law of the Member State. All rights reserved | ACSS 65  EU Internal Compliance Program For Dual-Use Controls Commission Recommendation under Council Regulation (EC) No 428/2009 This 2019 guidance is of a non-binding character 7 Essential Elements https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32019H1318&from=EN All rights reserved | ACSS 66  Wrap Up and Q&A All rights reserved | ACSS 67  What we covered UN Sanctions Overview and legal foundation Listing, process, delisting How to read a UNSC resolution EU Sanctions Overview and legal foundation Listing, process, delisting Enforcement All rights reserved | ACSS 68  Q&A Please submit any questions in the chat box. All rights reserved | ACSS 69  Thank You! Next Session is Next Week - Tuesday 12:00 – 2:00 pm ET Sanctions Imposers and Targets: Spotlight United States Visit Us Here : www.sanctionsassociation.org