The Office for Statistics Regulation (OSR) would like to see greater transparency and clarity around statistics relating to UK asset freeze targets under the Russia regulations.
There is considerable media and public interest in the effectiveness of UK asset freeze targets under the Russia regulations. The Foreign, Commonwealth and Development Office is the Government department responsible for making UK sanctions designations and maintains the UK sanctions list, regularly announcing updates to the list of sanctioned individuals and organisations.
HM Treasury’s Office of Financial Sanctions Implementation (OFSI) regularly updates and makes public a the list of targets (e.g. people, banks, institutions) of financial sanctions including asset freezes, but the values of assets for each individual target is not known and thus not listed. However, estimates of the total global assets of targets have entered public debate. We found it difficult to find a public source for these estimates.
Transparency and clarity are the key elements in avoiding the risk of misinterpretation or misleadingness in statistics about sanctions. We encourage those making statements about the impact of financial sanctions to point to readily available material to support understanding of the statements being made. In doing this, it is hoped that transparent and fair public debate can be helped on the issues that matter as opposed to the validity of the data in question.
When estimates of the values of UK financial sanctions are being issued by government, those publishing should follow the OSR’s Regulatory guidance for the transparent release and use of statistics and data.
The guiding principles behind OSR’s regulatory guidance on intelligent transparency
- Equality of access: Data quoted publicly, for example in parliament or the media, should be made available to all in a transparent way. This includes providing sources and appropriate explanation of context, including strengths and limitations.
- Understanding: Analytical professions need to work together to provide data which enhances understanding of societal and economic matters, including the impacts of policy. Governments should consider data needs when developing policy and be transparent in sharing analytical and research plans and outputs with the public.
- Leadership: Organisations need strong analytical leadership, within and beyond analytical professions. Decisions about the publication of statistics and data, such as content and timing, should be independent of political and policy processes. These decisions should be made by analytical leaders, who should also be given freedom to collaborate across organisational boundaries to support statistics that serve the public good. Their expertise and decision-making authority should be endorsed by Permanent Secretaries.
Policy, press or ministerial statements relating to UK financial sanctions
The Code of Practice for Statistics is clear that policy, press or ministerial statements referring to statistics should contain a prominent link to the source of these statistics, which is clear on any limitations and appropriate use. The Code looks to professional standards of statistical presentation being upheld, including accuracy, clarity and impartiality.
Official sources of data on UK financial sanctions
The website of the Office of Financial Sanctions Implementation (OFSI) contains the latest data on the targets of UK financial sanctions. Each year OFSI carries out a review of frozen assets held by UK institutions which it publishes in an annual review. Relevant UK firms (a list of relevant firms for example in financial services, legal, insurance is set out in the legislation) who hold frozen assets (including funds and economic resources) are required to report them to OFSI. OFSI follows the principles of the Code of Practice for Statistics and ensures that reports submitted for the Frozen Asset Review are accurate. The OFSI Annual Review is published every autumn on gov.uk and includes the data for frozen assets as reported in the previous September, the last review being published in September 2021.
Who else can the media and members of the public look to for guidance on understanding announcements about sanctions?
There are several fact-checking organisations which tend to investigate public statements made by the government. These include Full Fact, BBC Reality Check, Channel 4 Fact Check, FactCheckNI and The Ferret. These organisations often produce helpful summaries of the data and information which supports the statements being made and help clarify any elements which may be open to misinterpretation.
Tips for statistics producers on urgent quality assurance of ad-hoc statistical analysis
There are well-established and documented Quality Assurance (QA) processes in place for Government Statistical Service (GSS) statistical outputs. However, often there is a need for additional ad-hoc analysis of official data, with a quick turn-around, to answer a specific question. Even when time and resources are limited, the analysis still requires good QA to avoid costly mistakes. The GSS Quality Centre has developed some top tips to improve the QA of ad-hoc analysis across the GSS.