Report D-14 examines the procedural safeguards available to individuals and entities subject to targeted sanctions in the European Union, the United Kingdom and the United Nations Security Council system. It focuses on notification, reasons for designation, access to relevant material, the right to be heard, confidential evidence, independent review and the implementation of favourable decisions.

The report’s central conclusion is that the mere existence of a formal complaint mechanism does not amount to effective legal protection. A designated person needs to understand what decision has been taken, which facts support it, how those facts can be challenged and which independent body is capable of reviewing the decision. Confidentiality must also be distinguished from evidentiary reliability: protected information may still be incomplete, outdated or incorrectly attributed to a particular person.

Within the EU, particular importance is attached to reasoned individual decisions and judicial scrutiny of their factual basis. The Kadi II case illustrates that, when adverse grounds are challenged, the competent authority must substantiate them rather than requiring the affected person simply to prove their absence. In the United Kingdom, the framework combines administrative review under SAMLA, judicial review and special procedures for closed material, including the use of special advocates.

The report separately analyses the United Nations system, distinguishing the Ombudsperson mechanism for the ISIL and Al-Qaida sanctions list from the Focal Point for Delisting applicable to other relevant Security Council lists. Particular attention is given to the reform of the Focal Point and the new Coordinator taking office on 1 September 2026. The report cautions, however, that the start of the reformed mechanism does not yet provide sufficient evidence to assess its long-term effectiveness.

ARGA ultimately presents procedural protection as an interconnected sequence: notification opens the possibility of defence; reasons define what must be challenged; access to information makes a meaningful response possible; independent review tests the authority’s position; and implementation converts a legal finding into a practical change. Secrecy, urgency and foreign-policy considerations may justify particular procedural adaptations, but they do not eliminate the need for an individualised and reviewable basis for restrictive measures.