Tactics of Sanctions Evasion in Syria
31 January, 2022 - Despite ten years of western sanctions on Syria, the Syrian regime has managed to survive and adapt to pressure. Sanctions were imposed on the Syrian regime as a response to its human rights violations since the beginning of the popular Syrian uprising in 2011. Economic sanctions sought to hinder the regime’s ability to commit further violations, by depriving it of the resources it needs, as is the case with sanctioning oil imports to Syria, used to fuel the regime’s air force and army. It also aimed to pressure the Syrian regime to change its behavior and engage in a political process based on UNSCR 2254.
Targeted sanctions against individuals, including businesspersons, sought to tighten the grip on the regime’s finances and further cripple its war machine. However, over the course of the past ten years, leaked documents and investigative reports documented various methods of sanctions evasion adopted by the Syrian regime and sanctioned businesspersons. Such practices often intersect with money laundering strategies, and include the extensive use of shell companies, obscuring the origins of payments through complex money transfers, relying on the services of banks of dubious reputations, among others.
While the full scale of the sanctions evasion’s effect is not fully measured, it has helped shoring up the regime’s resources during the past decade. The strengthening of the sanctions’ programs with secondary tools, such as the US Caesar Act 2019, has managed to tighten the grip further on sanctions evasion. However, the Syrian regime and its cronies increasingly tend to adapt to the new sanctions by developing their evasion tactics. This research paper aims to explore the methods through which the businesspersons supporting the Syrian regime evade sanctions, and to highlight practical recommendations to concerned states on how to close these loopholes. This, in turn, aims to strengthen the limited accountability measures available for Syria, in light of the absence of an international agreement. Increasing the effectiveness of sanctions also strengthens its chances of achieving its second declared goal, namely changing the behavior of human rights abusers.
