States, firms, and security: How private actors implement sanctions, lessons learned from the Netherlands

Abstract

While the current practice of the United Nations Security Council, the European Union, and the United States leans towards imposing only targeted sanctions in most of the cases, private actors often complain about inability to process financial transactions, ship goods, or deliver services in countries where sanctions targets are located. The impact of sanctions often ends up being widespread and indiscriminate because sanctions are implemented by for-profit actors. This article investigates how for-profit actors relate to the imposition of sanctions, how they reflect them in their decisions, and how they interact with the public authorities. The findings of our research show that for-profit actors, with the possible exception of the largest multinationals, do not engage with public authorities before the imposition of sanctions. The behaviour of for-profit actors in the implementation phase is in line with the assumption of firms and business as profit-maximisers. Weighting the