... Hundreds of businesses continue to operate freely and without consequence in some 250 settlements Israel has erected. In March 2016, member states of the UN Human Rights Council (HRC) decided to act on this issue: Through HRC resolution 31/36 they tasked the UN Office of the High Commissioner of Human Rights (OHCHR) with setting up a database of such businesses and reviewing it annually. The OHCHR announced in a January 2018 report that it had created a list of 206 businesses, the names of which it intends to disclose “in a future update.” The database is a unique transparency tool and soft power enforcement mechanism that could provide a service to states and their corporate nationals who may become involved in illegal business activities. Many states realize that the initiative is an opportunity to develop a blueprint for a tool that would monitor activities in high-risk business environments not only in Israel’s settlements, but in other ongoing cases of occupation and annexation... [T]he OHCHR is tasked with providing interpretative guidance on the ways in which companies and individuals acting as procurers, investors, and consumers may contribute to and benefit from violations of international law in occupation. While many such cases may not meet the high threshold of civil and criminal liability for complicity, they may still be liable to legal risks under provisions of domestic law of the business’ domicile country...