The United States uses financial sanctions as a prominent tool of foreign policy. While this tool is used with increasing frequency and popularity, there is relatively limited publicly available information measuring the instances of U.S. sanctions designations and delistings. While no quantitative list or specific number of designations can exactly gauge the coercive pressure applied on a target or the efficacy of using sanctions, CNAS is launching a sanctions data-tracking project to give basic information about U.S. sanctions designations and delistings. This data-tracking project is designed to help evaluate the nature, form, reach, and modalities of U.S. sanctions over time. This is the first presentation of data for the CNAS project. It overviews the last ten years of U.S. sanctions, during which time there as been a marked rise in designations and the use of financial sanctions as a core instrument of foreign policy.1
Total Sanctions by the Numbers
After a relatively constant number of sanctions designations annually during the Obama administration, the number of designations markedly increased during the first two years of the Trump administration. The 2019 total, though lower than 2017 and 2018, was higher than any year under President Obama. Despite high-profile cases of removing individuals and companies from sanctions, notably the Russian aluminum company RUSAL, overall the Trump administration has delisted fewer entities over the last several years.
Note: Data includes all Specially Designated Nationals, Foreign Sanctions Evaders, CAPTA, and Part 561 List Identifications and Sectoral Sanctions Identifications.
Total U.S. Sanctions Designations and Delistings by Year, 2009–2019
Sanctions by Category
The U.S. government groups sanctions designations and delistings into four categories: individuals, entities, vessels, and aircrafts. While trends in designations and delistings have changed over time, the relative proportion of each category notably has stayed similar.
Designations by Category by Year, 2009–2019
Delistings by Category by Year, 2009–2019
Sanctions Designations by Program
The number of sanctions programs has increased to cover new issues and target new countries, behaviors, and even types of transactions. While only half of the sanctions programs used in 2009 were used in 2019, they account for the largest share of enacted sanctions.
Sanctions Programs in 2009 and 2019
Burma includes all entities sanctioned pursuant to Executive Orders 13619 and 13651.
Counternarcotics includes all entities sanctioned pursuant to EO 12978 and the Foreign Narcotics Kingpin Designation Act.
North Korea includes all entities sanctioned pursuant to EOs 13687, 13722, and 13810.
Nicaragua includes all entities sanctioned pursuant to EO13851 and the Nicaragua Human Rights and Anticorruption act of 2018.
Iran includes all entities sanctioned pursuant to the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010, the Iran Human Rights and Hostage-Taking Accountability Act, the Iran Threat Reduction and Syria Human Rights Act, as well as EOs 13553, 13608, 13846, and 13876.
Ukraine includes all entities sanctioned pursuant to EOs 13660, 13661, 13685.
Russia/SSI includes all entities identified pursuant to EO 13662.
Magnitsky includes all entities sanctioned pursuant to the Sergei Magnitsky Rule of Law Accountability Act of 2012 and the Global Magnitsky Human Rights Accountability Act.
Venezuela includes all entities sanctioned pursuant to EOs 13692, 13850, and 13884.
Regarding the methodology used for this effort to examine sanctions by the numbers, the author and reviewers acknowledge the difficulty in assessing the use of sanctions while avoiding statistical distortions. In an effort to reduce misconstruction, we count a designated entity as designated once, at the time of its first inclusion in any sanctions program, regardless of the number of programs it falls under at the time of the initial designation. Additionally, we count a named entity only once even if it has multiple subsidiaries or vessels. We track all sanctions authorities used at the time of designation, and, when evaluating the use of these programs, include all programs in the tally. Conversely, we count delistings only when all sanctions designations under every authority are removed and the entity is no longer on the sanctions list. We think this allows for the most accurate comparison across programs, years, and presidencies.
The author would like to thank Neil Bhatiya, Peter Harrell, Elizabeth Rosenberg, and Adam Smith for their review of this project, as well as Maura McCarthy, Melody Cook, and Loren DeJonge Schulman for their assistance with the production of this project.
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