Sanction

Pull back the curtain on wars, mass atrocities, and other human rights abuses, and you’ll find grand corruption and unchecked greed. These tragedies persist because the perpetrators rarely face meaningful consequences. CFJ’s strategic partner The Sentry aims to alter the warped incentive structures that continually undermine peace and good governance. Their investigations follow the money as it is laundered from war zones to financial centers around the world. And they provide evidence and strategies for governments, banks, and law enforcement to hold the perpetrators and enablers of violence and corruption to account. These efforts provide new leverage for human rights, peace, and anti-corruption efforts.

One of the tools used to disrupt these networks is targeted sanctions. When designed, implemented, and enforced thoughtfully and transparently, targeted network sanctions and other forms of disruption techniques can be a powerful tool in addressing a variety of threats to regional and international stability, including terrorism, nuclear proliferation, drug trafficking, organized crime, armed conflict, corruption, and human rights abuses.

Influencing Policy

The Sentry has long advocated—including in a research paper in 2019 and, more recently, in Congressional testimony and in a briefing to the administration—that sanctions should be one tool in a larger pressure strategy designed to reach a clearly stated goal, as opposed to a standalone policy, and that they should be deployed multilaterally in concert with allies.

In December, the Biden administration announced a new strategy to counter corruption and illicit finance.

The new policy followed on the heels of the much-anticipated sanctions review, published by the US Department of the Treasury in October. The Sentry provide inputs at several stages into both, and was the only NGO to be included both in initial consultations and in a roundtable with human rights and anti-corruption NGOs related to the sanctions review.

The US Department of the Treasury also announced steps to tackle the abuse the US real estate market by illicit actors.  The Sentry’s report Embezzled Empire, which investigated dirty money stashed in real estate just a stone’s throw from Washington DC, was one of two NGO reports specifically cited in the advanced notice of proposed rulemaking.

 

Creating Consequences

International Enablers

In 2021, The Sentry focused on the cross-border networks and international enablers that facilitate the corruption that lies at the root of so much suffering around the world. Their persistent investigations and advocacy targeting corrupt business tycoons like Dan Gertler, Benjamin Bol Mel, and Al-Cardinal resulted in new and updated network sanctions against all three men and their companies by the US Department of the Treasury.

The Sentry has worked for years to create serious consequences for Dan Gertler and his network. He is responsible for looting significant amounts of the DRC’s natural wealth, and the combined efforts of The Sentry and other organizations resulted in sanctions imposed in 2017 under the US Global Magnitsky program.

 

Private Security Companies

Over several months, The Sentry has worked closely with CNN on a confidential investigation, obtaining testimony and documents implicating the Wagner Group, a shadowy Kremlin-linked defense and security firm, in an array of mass atrocities against civilians in the Central African Republic (CAR).

Following the investigation, The Sentry released a series of recommendations to governments and financial institutions around the world to help halt the ongoing atrocities in CAR. Subsequently, the European Union sanctioned the Wagner Group and a key representative of the group in the CAR for serious human rights abuses committed in the CAR.

You can read the full list of recommendations here.