• Attainment of Responsive Public Institutions. • Broad based Citizenry Participation in national and socio-economic development programmes. • Political and Economic Re-engagement with the global community. • Creation of a Competitive and Friendly Business Environment. However, the rules of IFIs require that Zimbabwe repay prior loans before accessing further funding. Zimbabwe is indebted to all relevant IFIs except the IMF, and therefore has not been eligible for loans over the more than two decades that it has been in arrears. Zimbabwe cleared its US$107,9 million debt with the IMF in October 2016. However, the pari passu rule requires that arrears are cleared with all IFIs to meet the condition. This entails Zimbabwe clearing the nearly 2.3 billion outstanding to the World Bank (U1.3bn), the African Development Bank (US$680m) and the European Investment Bank (US$308m).21 For this reason, ZDERA has never been implemented and the US has never voted against any loans to Zimbabwe. Loans to Zimbabwe had been suspended by the IMF and World Bank in September and October 1999 respectively, (i.e. before the land invasions in 2000 that are often cited as the initial catalyst22) according to ZDERA, because of “economic mismanagement, undemocratic practices, and the costly deployment of troops to the Democratic Republic of the Congo”.23 Implementation and effects Through ZDERA, Congress “has the sense” (i.e. suggests but does not require) that the US President should consult with the governments of European Union member states, Canada, the United Kingdom and Australia and other appropriate foreign countries when listing SDNs and locating their assets held outside Zimbabwe; to implement travel and economic sanctions against those individuals and their associates and families; and provide for the eventual removal or amendment of the sanctions.24 This does not appear to have happened and, as noted, the US SND list has not been regularly updated and revised in the manner of that of the EU. The lists of Canada, Switzerland, News Zealand and Australia generally named the same key individuals and entities as the EU. EU Sanctions Post-Mugabe As noted, only Grace Mugabe effectively remains subject to the EU’s assets and travel ban, with the commanders of the defence forces remaining on the list, but with the measures against them suspended. The arms embargo and measures against Zimbabwe Defence Industries remains. The EU’s National Indicative Programme funding has resumed and dialogue under Article 8 of Cotonou is again taking place (following concerns around the violence in mid-January 2019), launched on 5 June 2019 “to create greater understanding between Zimbabwe and the EU.” US Sanctions Post Mugabe The number of people and entities currently on the US SDN list is variously reported, as often the same people or entities are listed more than once with different names, or holding companies and 21 These are debts to multilateral lenders only bilateral debt to Paris Club and non-Paris club members amounts to another US$3.4 billion. 22 The Government of Zimbabwe often presents that the suspension of loans began as a response to its “Fast Track Land reform programme”. However, after the land invasions of February 2000, in May 2000, the IDA (read World Bank) suspended all other new lending to the Government of Zimbabwe and in September 2000, the IDA suspended disbursement of funds for ongoing projects under previously-approved loans, credits, and guarantees to the Government of Zimbabwe. 23 Section 4 of ZDERA. 24 Section 6 of ZDERA. 8