03
Chapter 3 · What caution costs
What caution costs
Sanctions work not only through prohibitions but also through the caution of those who comply with them. These figures are documented; they measure different things and cannot be added up.
was the global cost to financial institutions of complying with financial crime rules, according to a study of 1,181 professionals.
Source: LexisNexis Risk Solutions, press release of 26 Sep 2023
say the web of regulations and sanctions constrains their business; in Europe, the Middle East and Africa the figure is 80 percent.
Source: LexisNexis Risk Solutions, 26 Sep 2023, via Finextra
was paid by BNP Paribas in 2014 for violating US sanctions on Sudan, Cuba and Iran. The case concerned payments in US dollars through the US financial system.
Source: Al Jazeera, 30 Jun 2014
is the global average cost of a remittance. The measure is the cost of sending 200 US dollars.
Source: World Bank, Remittance Prices Worldwide, home page of 18 Aug 2025, accessed 3 Nov 2026
The Sustainable Development Goals call for reducing remittance costs to less than 3 percent, with no corridor above 5 percent.
Source: World Bank, indicator SI.RMT.COST.OB.ZS, target 10.c
confirmed that it was suspending transfers between the US and Cuba indefinitely, after the US had added the processor Orbit S.A. to its list of restricted Cuban entities.
Source: Bloomberg Línea, 10 Feb 2025
United Nations, 21 November 2025
What the Special Rapporteur found in Cuba
“De-risking policies and over-compliance have been substantially exacerbating the humanitarian situation.”
Alena Douhan, UN Special Rapporteur on unilateral coercive measures, visited Cuba in November 2025. In her preliminary statement she describes banks refusing to carry out any transaction and transport companies refusing to guarantee deliveries. Remittances, she writes, are officially exempt but have become hard to receive since Western Union withdrew in February 2025. Payments and procurement have become more expensive, slower and less transparent.
She calls on the US to lift the measures and on banks and companies to avoid over-compliance. At the same time she acknowledges Cuba’s primary responsibility for protecting human rights and calls on the government to cooperate with UN mechanisms and to host further Special Rapporteurs. The final report was announced for the Human Rights Council in September 2026.
Source: OHCHR, end-of-mission statement, Havana, 21 Nov 2025
European Banking Authority
De-risking can be a legitimate risk management tool, but when unwarranted it excludes people (5 January 2022). Guidelines of 31 Mar 2023, applicable since 3 November 2023: banks must consider several options before rejecting a customer and follow set steps before ending a relationship. Refusing entire categories of customers without looking at individual risk can be unwarranted. For the most vulnerable, such as refugees and homeless people, it can be a matter of survival.
Source: EBA, press releases of 5 Jan 2022 and 31 Mar 2023 (EBA/GL/2023/04); Finanssivalvonta, 2 Nov 2023
Report to the General Assembly
The Special Rapporteur’s report “Secondary sanctions, overcompliance and human rights” was submitted to the UN General Assembly on 4 September 2023. It examines how fear of penalties also prevents permitted business, aid and payments.
Source: United Nations, A/78/196 of 4 Sep 2023
Sources in this chapter
- LexisNexis Risk Solutions, press release of 26 Sep 2023
- LexisNexis Risk Solutions, 26 Sep 2023, via Finextra
- Al Jazeera, 30 Jun 2014
- World Bank, Remittance Prices Worldwide, home page of 18 Aug 2025, accessed 3 Nov 2026
- World Bank, indicator SI.RMT.COST.OB.ZS, target 10.c
- Bloomberg Línea, 10 Feb 2025
- OHCHR, end-of-mission statement, Havana, 21 Nov 2025
- EBA, press releases of 5 Jan 2022 and 31 Mar 2023 (EBA/GL/2023/04)
- Finanssivalvonta, 2 Nov 2023
- United Nations, A/78/196 of 4 Sep 2023
All references with dates are in the list of sources.