These difficulties emerge when overcompliance is used without prior assessment.
✅ blocking all financial transactions with a sanctioned target regardless of humanitarian exemptions or scope
✅ deterring authorised transactions
✅ freezing assets not targeted by sanctions
✅ preventing individuals from opening or maintaining bank accounts (…).
🏦 This report lists a series of recommendations for banks and financial institutions (measured compliance and over-compliance exclusion, monitor the human rights impact of their sanctions compliance policy, free flow of payments for goods necessary to guarantee the basic needs, etc.).