A foolish consistency is the hobgoblin of little minds... so saith Ralph Waldo Emerson. Why are sanctions so lacking in nuance? Why do regulators keep imposing asset freezes on parties with no assets and those who don’t conduct any international business? Having a “one size fits all” approach surely does not aid in sanctions’ effectiveness, and surely imposes a cost in efficiency for all who conduct sanctions compliance screening. Today, I’ll discuss a model which I suspect would both be more effective and more efficient.... the veritable sweet spot for things that both companies and governments strive for.