Financial Sanctions

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Can China Lead the Way in Constraining Economic Coercion? Sanctions, Chokepoints, and the Perils of Convergence

July 22, 2026

Economic coercion remains ill-defined in international law, but its importance is growing ever more evident by the day. At various points, for example, a negotiated settlement to the US-Iran War has reportedly been blocked in key part by disagreements over $24 billion in assets frozen by the US Office of Foreign Assets Control (OFAC); most of which was targeted after the 2018 unilateral US withdrawal from ‘The Joint Comprehensive Plan of Action’. Stored in third country banks, the funds largely consist of accumulated oil revenues. They were thus frozen only because OFAC enforces secondary sanctions. These operate on an extraterritorial basis, targeting non-US persons and entities for transactions occurring entirely outside US territory and with zero domestic nexus. OFAC leverages the asymmetrical opportunities provided by “dollar hegemony“, coercing firms by threatening to cut them off from US dollar clearing and correspondent banking, as well potentially imposing considerable financial (or even criminal) liability. Since their 1990s proliferation, US…

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Who Pays for Aggression? Ukraine’s Reparation Claims and Russian Frozen Assets

July 17, 2026

As Russia’s war against Ukraine rages, inflicting suffering on the country, its people, and economy, the Russian Central Bank (RCB) assets remain immobilised (i.e., frozen). Since December 2025, the EU, on whose territory a significant chunk of these assets has been immobilised, – €210 bn worth of assets out of approximately €290 bn  – modified the legal…

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Central Bank Sanctions Return to the CJEU

March 20, 2026

A Primer on the Russian Central Bank’s Legal Challenge to the Permanent Freezing of its Assets On March 3, 2026, the Central Bank of Russia (CBR) announced that it has recently filed an action for annulment under Article 263 TFEU challenging Council Regulation (EU) 2025/2600 before the General Court of the EU. This regulation…

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Offsetting Inter-State Debt in International Law

January 6, 2026

Since the immobilization of Russian Central Bank (RCB) assets across multiple jurisdictions in response to Russia’s aggression against Ukraine, officials and commentators have debated the legal permissibility as well as the political and economic wisdom of using those assets to fund Ukraine’s defense and reconstruction. While the EU has agreed to issue a loan to Ukraine backed by…

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Fifteen Years of the UN Ombudsperson: Due Process as Competitive Advantage

September 23, 2025

This year marks the 15th anniversary of one of the most quietly revolutionary institutions in global governance: the Office of the United Nations Ombudsperson to the ISIL (Da'esh) and Al-Qaida Sanctions Committee. The Office was established by the Security Council to provide an independent, impartial review mechanism for those on the counterterrorism sanctions list.

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