UK Foreign Secretary Dominic Raab recently announced that Four Zimbabwean security sector chiefs responsible for serious human rights violations – including the deaths of 23 Zimbabwean protestors – have been designated under the UK’s new autonomous sanctions regime. The sanctions mean that these individuals cannot freely travel to the UK, channel money through UK banks or profit from the economy. These restrictive measures are not targeted at the broader economy and the people of Zimbabwe.

These designations are the first the UK has made of individuals under the UK’s Zimbabwe autonomous sanctions regime, which came into force at 11 pm on 31 December 2020.

The individuals involved include:

• Owen Ncube, Minister for State Security
• Isaac Moyo, Director General of the Central Intelligence Organisation
• Godwin Matanga, Commissioner General of the Zimbabwe Republic Police, and
• Anselem Sanyatwe, former Brigadier General, Commander of the Presidential Guard and Tactical Commander of the National Reaction Force

These individuals are accused of being responsible for the worst human rights violations against the people of Zimbabwe since President Emmerson Mnangagwa took power in November 2017. Their crimes include a state-sponsored crackdown against protests in January 2019 that resulted in the deaths of 17 Zimbabweans and post-election violence in August 2018 in which six protestors lost their lives.

Why is this important for your organisation?

Non-compliance with sanctions is one of the key risks which organisations face. Failure for internal compliance procedures to keep up with a list of sanctioned regimes, entities or individuals put companies at the risk of fines from regulators. On the other hand, organisations themselves need to be committed to strong economic, social and governance principles to avoid being sanctioned by governments. They need to be especially careful when working in countries with poor track records in governance, corruption, and human rights.

Recommendations

• Strengthen your firm’s internal control framework to mitigate sanctions risks.
• Implement a robust due diligence and sanctions screening system sensitive to the level of risk to which your organisation is exposed.
• Implement clear sanctions escalation procedures within your organisation to help identify and resolve sanctions issues that do arise.
• Promote a culture of compliance amongst your staff and your business partners.
• Subscribe to platforms like the Africa Compliance Hub (ACH) to receive regular updates on sanctions and compliance issues in Africa.

You can learn more here.