INTRODUCTION

The institutional measures that regional organizations apply against their member States are often excluded by the current legal debate on sanctions, on the assumption of their lawfulness insofar as they are governed by their own constituent instruments. However, the imposition of sanctions has become a crucial component of regional governance: while the first decade after the end of the Cold War was characterized by the economic measures adopted by organizations such as the Economic Community of West African States (ECOWAS) and the Organization of American States (OAS) – the latter subsequently less active in this field – in recent years it has been the African Union (AU) that has played a very active role, imposing both the suspension of various countries from membership and targeted sanctions as a reaction to unconstitutional changes of government. Even the Arab League, a regional organization that has traditionally been suspicious vis-à-vis sanctions, has used this tool in relation to Syria and Libya. Yet other regional organizations have continued to remain reluctant with respect to measures that represent, in their view, an unlawful interference with the internal affairs of States: this is the case with the Association of Southeast Asian Nations (ASEAN), whose members refused to include a sanction mechanism in their 1998 Charter.

This contribution suggests the adoption of a comparative perspective with the purpose of charting the great variety of practice and offering an analytical tool for assessing similarities and differences in the conduct of regional organizations.