Episode #292: A Sanctioned Resistance

 

“I don't think sanctions alone will be able to end the conflict,” says Anrike Visser, a Senior Policy Advisor at The Sentry. “Doing more in terms of enforcement, collaborating better with civil society organizations, I think the impact of the sanctions would be a lot bigger than it is today.”

The Sentry is an investigative and policy organization that seeks to disable multinational predatory networks that benefit from violent conflict, repression, and kleptocracy. It was co-founded by the famous actor, George Clooney, and John Prendergast, and has engaged in the crises in Sudan, South Sudan, the Democratic Republic of Congo, Zimbabwe, Central African Republic, and more recently in Libya and Myanmar. In its own words, The Sentry describes its mission as follows: “Pull back the curtain on wars, mass atrocities, and other human rights abuses, and you’ll find grand corruption and unchecked greed. The Sentry aims to alter the warped incentive structures that continually undermine peace and good governance. Our investigations follow the money as it is laundered from war zones to financial centers around the world. We provide evidence and strategies for governments, banks, and law enforcement to hold the perpetrators and enablers of violence and corruption to account.”

Anrike’s work in the organization focuses on economic statecraft—the strategic use of economic tools by states to influence international relations and achieve foreign policy objectives—and leading partnerships with European governments and institutions like the IMF and World Bank. She has experience in financial regulation and has worked on investigations into “violent kleptocracies” in Africa and Myanmar.

Before delving into the complex issue of sanctions regarding Myanmar, Anrike provides some background. She explains that economic statecraft has gained momentum as a diplomatic tool, particularly following the invasion of Ukraine by Russia. “Especially in active conflicts, like Myanmar and the recent coup d'etat, it's really become a tool that is used a lot more often now,” she says. She believes that closer collaboration between the EU, US, and UK strengthens the sanctions’ impact.

However, as the opening quote illustrates, to be truly effective, sanctions need to be part of a broader approach that includes diplomacy and aid, and clearly communicate both punishment-based and incentive-based elements (such as IMF loans, which often include requirements like anti-corruption frameworks). Then, if conditions aren’t met, there must be strict enforcement, ensuring transparency and accountability for positive outcomes. Finally, Anrike believes that sanctions should be targeted at specific sectors, like arms, teak, and gems, where Western markets dominate and therefore have leverage.

Anrike goes on to explain the complex mechanism of international sanctions: “Targeted network sanctions [are] specifically where we go for specific companies and individuals active in certain human rights abuses or undermining democracy, and we target those specifically and try to prevent civilian harm.” In Myanmar’s case, sanctions on sectors like garments have been avoided because, although revenue to the junta from these sectors is minimal, they provide essential jobs for thousands of women. She mentions that targeted sanctions restrict individuals from traveling to places like the EU and freeze their assets held in foreign currencies, such as USD, which is critical for Myanmar’s economy. These measures also prohibit trade with sanctioned companies, aiming for impactful pressure while minimizing harm to civilians.

Anrike notes that while sanctions alone may not immediately end a regime, they can significantly reduce a junta's access to resources, making oppressive actions harder to sustain. “We shouldn't underestimate the impact that sanctions can have. And there's some statistics that indicates that at least some abilities of the junta over these last three years have been reduced,” she points out. Even isolated regimes often rely on foreign assets; elite figures seek safe havens for their wealth, education for their children, and shopping access abroad. Thus, cutting these off impacts them and their supportive networks, including organized crime. However, she highlights the need for strict enforcement to close loopholes. “If there's no enforcement, if there's no consequences, then it's just a paper tiger and they continue to have access to the west, even though they shouldn't.”

In Myanmar’s case, she emphasizes that economic measures are essential to deprive the junta of resources. “I think just statements or diplomacy alone is not effective enough,” she argues, adding that governments should adopt more economically forceful measures if military intervention is neither viable nor desired by the local population. Reflecting on the period between 2016 and 2021, she notes that the lifting of sanctions was framed as a way to encourage positive change through economic incentives, and while this approach achieved limited success, it ultimately failed as the junta continued its oppressive actions, including systemic human rights abuses. “I think it is the time to be more forceful and to make sure that any of the funding or money that goes into the country cannot be misused to conduct these atrocities,” she asserts.

Anrike explains how sanctions are complex, and vary by currency and jurisdiction. The EU can freeze assets in euros, while the US has authority over USD transactions, even those outside its borders, due to USD's ties to US banking systems. This creates gaps if only one of these powers imposes sanctions, allowing sanctioned individuals to exploit legal access to European or American markets depending on where they are sanctioned. However, private banks often also impose additional restrictions to avoid risks. “Some banks have their own private policies,” she says. “They are private companies. They can set their own risk appetite.” She believes that broad cooperation across jurisdictions is essential for effective sanctions, as gaps weaken the overall impact.

Anrike points out how sanctions and banking restrictions have impacted the junta's financial operations, especially as it impacts their ability to purchase arms. “The UN Special Rapporteur on Myanmar just released a report on the use of regional banks and found that it decreased by a lot , around 90%, the use of Singaporean banks.” As a result, many have shifted to Thai banks, though the ability to procure arms has dropped by about 30% due to higher costs, risks, and difficulties in setting up new proxies. “Our goals shouldn't be—and can't be—that we are going to fully eradicate all transactions,” she says. “But with every enforcement action, you can reduce it a lot!”

As far as pressuring other countries that still have a heavy investment in Myanmar is concerned, like Vietnam, she thinks that it would be very challenging, and she is not even sure if Vietnam would be at all inclined to counter the junta. Nevertheless, she suggests that diplomatic efforts and ongoing pressure, particularly ASEAN members, could further restrict the junta’s access to financial networks.

Exploring a different avenue, Anrike suggests that engaging China in diplomacy could be effective. China maintains strong ties with the junta, and also has significant economic interests in achieving a stable Myanmar, such as the oil pipeline and port access. She believes that while China may not align with Western, human rights narratives, they do share the goal of reducing instability. “I think if you change the narrative and say, ‘Okay, can we work together and maybe talk about how to reduce the violence in the country?’,  that is definitely something that I think we could talk to China about,” In addition, she points out that while China’s government may not fully support Western sanctions, some Chinese institutions, like the Bank of China, have occasionally complied with sanctions to avoid risks. “I think it's important to see where's their overlap? How can we work together if we have the same goals?”

But she again emphasizes the overall priority in assessing the efficacy of a sanctions regime: “We don't want to hurt the regular people of the country!” This is why targeted sanctions are only intended to impact military generals, cronies and their associates. “I don't think the junta is affected if the 66th Light Infantry Division is sanctioned because of a massacre they did in Karenni state,” referring to the infamous unit accused of committing various war crimes throughout the country. However despicable their actions, the overall bite of sanctions targeted against them specifically would be minimal.  “Identifying the right targets is definitely an important aspect.” While industry sectors are usually not targeted, one exception is the oil and gas sector, particularly Myanmar Oil and Gas Enterprise (MOGE), because it directly funds the military. Anrike also supports sanctions on industries like timber, specifically teak, which contributes significant revenue to the authorities. “Of course, since we have the sanctions, there are a lot of attempts to circumvent them, especially in terms of the certificates that are provided,” she says. While Burmese teak is widely used, illegal trade persists as companies use fake certificates to circumvent sanctions. “These sanctions have been in place, and this isn't enough. I think jurisdictions really have to enforce and make sure that there's consequences!” She believes that stricter enforcement, including confiscating illegal teak, investigating certificates, and imposing fines is needed to halt illegal operations effectively.

Practically speaking, Anrike acknowledges the inadequate enforcement mechanism for sanctions. “The main problem when it comes to sanctions, is the difficulty or the lack of resources made available to enforce them,” she says. For example, port officials might receive shipments with apparently legitimate paperwork, but that masks illegal imports, yet they might just be too overloaded to check the documents thoroughly. Despite challenges like these, she thinks there has been significant progress in enforcement mechanisms over the last decade, with advancements like price-tracking databases and other technologies that help flag suspicious transactions. In the same vein, she emphasizes the growing awareness of the ways some try to evade sanctions, and legislative progress in stopping them—such as recent EU laws targeting "enablers" who support sanctioned activities. However, enforcement gaps persist, particularly in countries like the U.S., which still need to enact similar measures. “I think we will get there. But it takes time, and it's a major gap today,” she says. Another issue is that sanctions enforcement relies too heavily on information provided by companies themselves.

After sanctions have been applied, it is important to monitor and evaluate their actual effectiveness; however, this is not a straightforward task. “The impact of sanctions is difficult to measure in some instances, because of lack of data, [or] because governments don't want to admit that they have an impact,” Anrike says. She explains that while sanctions do have tangible effects—such as reducing the junta’s ability to procure weapons and recruit soldiers—they alone are not enough to dismantle the dictatorship, and must be part of a broader strategy. Diplomatic efforts, regional pressure, and cutting off access to critical resources like jet fuel must complement sanctions to maximize their impact and strain the junta's capacity to operate.

Anrike advocates a unified approach across nations like the US, EU, UK, Canada, and Australia, targeting the same individuals and sectors to avoid loopholes. She believes that enforcing sanctions more rigorously and in an overlapping way that closes any gaps is one part of the equation. Another is close collaboration with civil society organizations (CSOs), which can play an important role in strengthening sanctions regimes by providing critical, detailed, local information that is often missing from official dossiers. In Myanmar's case, where names and aliases are often similar, CSOs can assist banks and authorities in distinguishing sanctioned individuals.

Of course, the junta does not just sit idly by. Anrike says flatly, “The junta is trying to do everything it can to make sanction designations as difficult as possible.” For instance, Myanmar’s corporate registry was taken offline in 2022, and this limits transparency around new companies that may have been set up specifically to evade sanctions. “If you go through the trouble of identifying a person and submitting a sanction designation, we want to make sure that you have all the information that's needed,” she explains. So, because Myanmar’s CSOs have experience and wide networks that have endured decades of oppression, they provide invaluable information that sanctions teams can leverage, to counter the junta’s evasive tactics.

Anrike ends the conversation by emphasizing that The Sentry’s effectiveness stems from their collaboration with local groups like Justice for Myanmar, local media, and CSOs. In closing, she calls for the international community to step up and support these local organizations, who are doing so much while in harm’s way. She says: “I just want to acknowledge that they are the ones that should receive a lot more support from the international community, financial, training, capacity, just to keep doing this work under these difficult circumstances.”

Shwe Lan Ga LayComment