Independence requires more than the absence of improper influence. It requires that interests capable of affecting — or reasonably appearing to affect — institutional judgment are identified, assessed and appropriately managed.
This Conflict of Interest Policy establishes the principles applied by the International Sanctions Delisting Commission (“ISDC”) to actual, potential and perceived conflicts arising in its research, review, editorial and institutional activities.
Why Conflict Management Matters
Sanctions review may involve governments, designated persons and entities, legal representatives, commercial organizations, financial interests, politically exposed individuals, researchers and other stakeholders whose interests may differ materially.
The credibility of an independent review therefore depends not only on whether a conclusion is substantively justified, but also on whether the process used to reach that conclusion is sufficiently independent.
ISDC seeks to identify circumstances in which a reasonable observer could question whether a person’s judgment, participation or decision might be affected by another interest or relationship.
Relevant interests and relationships should be identified before they can influence institutional work.
Disclosure alone is not sufficient. The significance of the interest must be evaluated in its actual context.
Where necessary, safeguards, independent review, restricted participation or recusal should protect the integrity of the process.
Who This Policy Applies To
This policy applies, as appropriate to their role, to persons who participate in substantive ISDC institutional activity, including research, case assessment, evidence review, editorial decision-making, governance and other functions capable of influencing an institutional conclusion.
The policy may also be applied to external experts, consultants, advisers or other contributors where their involvement is sufficiently material to a review or publication.
What Constitutes a Conflict of Interest?
A conflict of interest may arise where a secondary interest, relationship or obligation could improperly influence, could reasonably be expected to influence, or could reasonably appear to influence the performance of an ISDC responsibility.
A conflict does not necessarily imply misconduct. In many cases, the relevant issue is whether the circumstance has been disclosed and appropriately managed.
A current interest or relationship materially interferes with the independent performance of an ISDC responsibility.
Example: direct financial or professional involvement in the matter currently under review.A circumstance exists that could develop into a material conflict as the person’s role or the review progresses.
The appropriate response may depend on the person’s future involvement and the significance of the issue.The circumstances could reasonably create an appearance that institutional judgment may not be independent, even where no improper influence has actually occurred.
Institutional credibility may require management of reasonable perceptions as well as actual influence.Would a reasonable and informed observer, knowing the relevant circumstances, have a legitimate basis to question the independence of the person’s judgment or participation?
Interests That May Require Disclosure
The relevance of an interest depends on context. Circumstances that may require disclosure include, among others:
- a financial interest in a person, entity or transaction materially connected with a review;
- current or recent employment, consultancy, advisory or professional engagement involving a relevant party;
- representation of a designated person, applicant, authority or materially interested organization;
- a close personal or family relationship with a person materially involved in the matter;
- significant business relationships with a relevant person or entity;
- prior substantive involvement in the events, proceedings or decisions being examined;
- participation in advocacy, litigation or other activity directly concerning the specific designation under review;
- gifts, benefits, hospitality or other advantages capable of creating a material obligation or appearance of influence;
- any other circumstance that could reasonably call independent judgment into question.
What Is Not Automatically a Conflict
Expertise, professional experience or prior work in sanctions, international law, compliance, government, academia, finance or related fields does not by itself constitute a conflict of interest.
Similarly, knowledge of a person, institution or subject matter does not automatically disqualify someone from participating in a review.
The relevant question is whether the particular relationship or interest is sufficiently connected to the matter to affect, or reasonably appear capable of affecting, independent judgment.
Familiarity with a subject can create expertise. A material stake in the outcome can create a conflict. The two should not be treated as equivalent.
Political Views and Institutional Independence
Individuals may hold personal political, legal, academic or policy views. The existence of such views does not automatically establish a conflict.
ISDC’s concern is whether a relevant commitment, relationship or activity is sufficiently direct and material that it compromises — or reasonably appears to compromise — the ability to evaluate the particular case on its evidence.
Institutional analysis should not be altered to produce a politically preferred outcome.
Financial Interests
A direct material financial interest connected with the outcome of a review should be disclosed and may require restricted participation or recusal.
Assessment should consider the nature, proximity and materiality of the interest rather than relying solely on its formal legal structure.
Professional and Advisory Relationships
Current or recent professional relationships may create a conflict where they involve a person, entity or issue directly relevant to the review.
Relevant circumstances may include legal representation, consulting, advisory work, employment, paid research, commercial services or other professional obligations.
The existence of a historical professional relationship does not automatically require exclusion. Its recency, significance and connection to the matter should be considered.
Case Applicants and Representatives
ISDC may receive submissions from designated persons, entities, legal representatives, advisers or other interested parties.
Providing information to ISDC does not give the submitting party a role in determining who conducts the independent assessment, how conflicting evidence is evaluated or what conclusion is ultimately reached.
Where a person involved in an ISDC review has a separate professional, financial or personal relationship with an applicant or representative, that relationship should be assessed under this policy.
Funding and Conflict of Interest
Financial support for institutional activity should not confer editorial, analytical or case-specific control.
A donor, sponsor, contributor or funding source must not be permitted to determine the factual findings or recommendation of a sanctions review.
Where funding arrangements create a material actual or perceived conflict, appropriate safeguards should be considered in conjunction with ISDC’s Funding Transparency and Institutional Independence standards.
Conflict Review Procedure
Where a relevant interest is identified, ISDC may apply the following process.
The relevant relationship, interest or circumstance is identified with sufficient information to permit meaningful assessment.
The nature, materiality, proximity and reasonable appearance of the conflict are considered in relation to the person’s actual responsibilities.
Where participation can continue without compromising independence, proportionate safeguards may be established.
Where safeguards are insufficient, the person may be excluded from some or all substantive participation in the relevant matter.
Material conflict determinations may be documented where appropriate to preserve accountability and consistency.
Available Safeguards
Conflict management should be proportionate to the nature and severity of the identified risk. Available measures may include:
Recording or communicating the relevant interest where transparency is sufficient to address the concern.
Requiring another appropriately independent person to review evidence, analysis or an editorial decision.
Permitting involvement in unaffected aspects of the work while excluding participation in the conflicted decision.
Removing the individual from substantive participation where the conflict cannot be adequately managed through lesser safeguards.
Transferring responsibility for a review, analysis or decision to another person where necessary to preserve institutional independence.
Recusal
Recusal may be appropriate where an actual conflict is material, where a reasonable appearance of partiality cannot be adequately addressed, or where continued participation could undermine confidence in the integrity of the review.
Recusal does not necessarily imply wrongdoing. It is an institutional safeguard designed to protect both the review process and the individual concerned.
The question is not whether a person believes they can remain impartial. The question is whether their participation can be justified under an independent and reasonable assessment of the circumstances.
Gifts, Hospitality and Benefits
Gifts, hospitality, favors or other benefits should not be accepted where they could reasonably be understood as intended to influence an ISDC decision or create an obligation in connection with institutional work.
Ordinary professional courtesies of insignificant value may not create a conflict, but context remains relevant. Particular caution should be exercised where a benefit is offered by a person with a direct interest in an active or anticipated review.
Confidential Information
Access to non-public information obtained through ISDC must not be used for personal, commercial or other unauthorized advantage.
A person must not use confidential case information to benefit a client, employer, investment, business interest or other third party.
Conflict obligations concerning confidential information may continue after a person’s participation in the relevant matter has ended.
External Activities
External professional, academic, advisory or public activities are not prohibited merely because they concern sanctions or related policy issues.
However, an external activity should be disclosed where it creates a material connection with a specific matter for which the person also holds an ISDC responsibility.
Duty to Update a Disclosure
Conflict assessment is not limited to the beginning of a review. Relevant circumstances may arise or change while work is in progress.
A person who becomes aware of a new material interest or relationship should disclose it without waiting for the review or publication process to conclude.
Failure to Disclose
Failure to disclose a material conflict may require reconsideration of the person’s participation and, where relevant, independent review of work previously performed.
The appropriate response should take account of the significance of the undisclosed interest, whether the omission was deliberate, and whether the integrity of a substantive conclusion may have been affected.
Effect on Published Work
Discovery of a conflict after publication does not automatically render the underlying research or conclusion invalid.
ISDC may assess whether the conflict could materially have affected the work and, where necessary, conduct an independent review of the relevant analysis.
If that review identifies a substantive problem, ISDC may issue a clarification, correction, revised assessment or other appropriate public update.
Public Disclosure
Not every disclosed interest requires public identification.
ISDC may disclose a conflict or conflict-management measure where doing so is materially relevant to understanding the independence or integrity of a public review, subject to legitimate confidentiality, privacy and legal considerations.
Questions and Reports
Concerns regarding a potential conflict affecting ISDC institutional activity may be submitted through the official ISDC contact channel.
A report should, where possible, identify the relevant matter, the nature of the alleged conflict and any information reasonably supporting the concern.
The existence of a complaint or allegation does not itself establish that a conflict exists.
Independence is protected not by assuming that conflicts will never arise, but by ensuring that they cannot quietly determine the outcome.
ISDC therefore treats disclosure, independent assessment, proportionate safeguards and recusal where necessary as components of institutional integrity rather than as presumptions of wrongdoing.