Sanctions Procedures and Procedural Safeguards: European Union, United Kingdom and United Nations

This report examines the procedural safeguards available to individuals subject to sanctions in the European Union, the United Kingdom and the United Nations system. It considers notification, statements of reasons, the opportunity to respond, access to supporting material, legal representation and independent review. Particular attention is paid to confidential evidence, closed material procedures and the distinction between protecting sensitive information and establishing a sufficient factual basis for restrictions. Drawing on legislation, institutional procedures and decisions including Kadi II and Al-Dulimi, the analysis compares the powers and limits of different review mechanisms. It examines the separate roles of the UN Ombudsperson and the Focal Point for Delisting, including the latter's 2026 transition. The report assesses how delay, relisting and implementation affect the practical value of safeguards, while distinguishing procedural defects from the separate questions of delisting, asset release and compensation.