For those who missed our debate on financing Ukraine reconstruction in the House of Commons last night, I thought I'd share some of the investigation I've been running into how we police sanctions evasion. My argument is simple: we'll have less to finance rebuilding Ukraine if we keep allowing Russian oligarchs to spend their ill-gotten gains which needs to be frozen and then seized.
But sanctions policing today is a mystery inside an enigma inside a riddle.
Some £18 billion of Russian money has now been frozen.
But oligarchs are able to spend some of the frozen money by applying to the Treasury for licenses, waivers and exemptions.
Once upon a time this used to be policed on a case-by-case basis with a careful review of every application to spend money.
But now the Treasury is issuing 'general licenses' for entire categories of spending. But! They won't tell us how much money oligarchs have been been allowed to move around.
What's more they are keeping secret exactly what is going on when it comes to what the licences are actually used for.
Ministers told the House of Commons that these licenses are issued by civil servants – under a 'delegated framework' for taking decisions.
But ministers are now refusing to publish the framework.
And when I asked for it under the freedom of information laws, I was refused – because the civil servants said the framework was "advice to ministers".
So - minister say the decisions on sanction waivers are down to civil servants - and civil servant say the governing framework is "advice to ministers"!
I am suspicious. Not least because ministers are also refusing to disclose how many criminal investigations there have been for sanctions evasion.
Worse, the office for financial sanctions implementation says the grand total of just two fines have been issued for sanctions busting - even though they record 147 reports of breaches of sanctions.
Bottom line: this stinks - And the bad guys may be getting away with freedom to enjoy their ill-gotten gains.